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2022 (11) TMI 613 - AT - Income TaxRevision u/s 263 by CIT - deduction claimed towards R&D expenditure incurred for Bio-pharma division - HELD THAT:- Assessee referring to annual report for the financial year 2012-13 argued that the assessee has generated revenue from Bio-pharma division, but there are certain doubts about the evidence filed by the assessee including annual report copy, because the assessee itself has filed a chart showing division wise revenue from operations as per which the assessee itself admitted that there is no revenue from operations from Bio-pharma division. AO without considering relevant facts simply allowed the claim of the assessee. Therefore, in our considered view, the assessment order passed by the AO is erroneous and also prejudicial to the interest of the revenue, because the AO failed to carry out required inquires or verifications which should have been made in the given facts and circumstances of the case. Thus, we are of the considered view that the PCIT has rightly invoked his jurisdiction and set aside the assessment order passed by the AO, on the issue of deduction claimed towards R&D expenditure incurred for Bio-pharma division. Hence, we are inclined to uphold the order passed by the PCIT u/s. 263 of the Act and dismiss the appeal filed by the assessee.
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