Partners not liable to pay tax on remuneration on which tax already paid by firm

H. R. International Vs PCIT (ITAT Amritsar) The section 263 has two limbs, the erroneous order and prejudicial to the interest of revenue. The assessee in its partnership deed mentioned the drawing power of the salary is 24 lakh per annum for each partner. In fact more than salary Rs. 24 lakh will be disallowed as per section 40(b)(v) of the Act. Here it cannot say that the specific salary is not quantified. The assessment order has not pointed out about anything related to partnership deed. But during calculation of total income the said deed was considered & documents was within the reco...