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2022 (3) TMI 71 - AT - Income TaxRevision u/s 263 by CIT - Deduction u/s 80P - HELD THAT:- The entire details called for during the assessment proceedings were submitted by the assessee at the time of assessment under Section 143(3) of the Act and the AO was very well aware that section 80P claim was reflected in the details of the assessee. The assessee vide letter dated 22.05.2017 submitted the details regarding deduction under Section 80P of the Act which was claimed in the return of income which included in the interest income from Mehsana Urban Co-operative Bank. PCIT has issued the show cause notice under Section 263 on 14.02.2020 on the very same issue which was verified by the Assessing Officer in Section 143(3) proceedings itself. Once the issue verified by the Assessing Officer and the jurisdictional Court has allowed the said claim related to interest income earned from Co-operative Bank, the PCIT cannot exercise Section 263 - A.R. aptly relied upon the decision of State Bank of India [2016 (7) TMI 516 - GUJARAT HIGH COURT] - PCIT cannot invoke provisions of section 263 - Decided in favour of assessee.
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