Revisionary proceedings u/s. 263 resulting into second opinion/ view of PCIT impermissible: ITAT Ahmedabad

Black Rock Financial Services Pvt Ltd Vs PCIT (ITAT Ahmedabad) ITAT Ahmedabad held that invocation of provisions of section 263 of the Income Tax Act by PCIT impermissible as exercise of such provisions amounts to second opinion/ view which is unsustainable in law. Facts- PCIT observed that the assessee accepted short term borrowing of Rs.1,72,76,00,000/- from Fortune Broking Intermediary Pvt. Ltd. However, the assessee did not show any interest income in Profit & Loss Account and, therefore, the proportionate disallowance of interest expenditure should have been made u/s. 36(1)(iii) of th...