Section 263 Invalid as AO Adopted One of Two Possible Views on Section 14A Disallowance

CIT Vs Future Corporate Resources Ltd. (Bombay High Court) In the case CIT vs. Future Corporate Resources Ltd., the Bombay High Court dismissed an appeal filed by the Revenue challenging an ITAT decision that had set aside an order under Section 263 of the Income Tax Act. The dispute arose from the PCIT’s revision of an assessment order for AY 2011–12, where the PCIT claimed that the Assessing Officer (AO) failed to properly examine interest expenses related to borrowings used for investment in subsidiaries and associate companies. The PCIT argued that since a portion of income from such i...