Section 263 Set Aside as AO’s View on Repairs Was Plausible and Not Prejudicial to Revenue

UBS Business Solutions (India) Pvt. Ltd. Vs PCIT (ITAT Pune) ITAT Pune Quashes 263: Cost-Plus Model Saves ₹21 Cr Repairs from Revision- 263 Fails Basic Test—Plausible AO View & Captive TP Model Protect Assessment Assessment u/s 143(3) r.w.s 144B was completed on 06.09.2022. PCIT initiated revision u/s 263 alleging that the AO had not verified whether repairs & maintenance expenditure of ₹21,02,01,617—including items like headsets, mouse, tiles, computer peripherals, & minor furniture—was capital in nature, & that the high proportion of repairs required deeper scrutiny...