Case Law Details
Kishorkumar Bhalara Vs PCIT (ITAT Rajkot)
The case of Kishorkumar Bhalara Vs PCIT (ITAT Rajkot) revolves around the jurisdictional aspects of Section 263 of the Income Tax Act, 1961. The appellant, Kishorkumar Bhalara, contested the order passed by the Ld. Principal Commissioner of Income Tax (PCIT), Rajkot-1, which invoked Section 263 to revise the assessment for the Assessment Year 2016-17.
Detailed Analysis
The crux of the matter lay in the PCIT’s assertion that the assessment order passed under Section 143(3) of the Act was erroneous and prejudicial to the interest of revenue due to alleged incorrect treatment of interest expenses under Section 57 of the Act. The PCIT contended that the Assessing Officer failed to adequately verify the claim of deduction for interest expenses.
However, upon examination, the ITAT found that the Assessing Officer had indeed conducted inquiries during the assessment proceedings regarding the deductibility of interest expenses. Moreover, the appellant had submitted detailed responses and justifications for the claimed deductions, both before the Assessing Officer and the PCIT.
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