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Trade Discount Not Commission: ITAT Quashes CIT’s Section 263 Revision for Overreach
Case Law Details
- Case Name
- Threepence Craft Vs CIT/ITO (ITAT Delhi)
- Appeal Number
- Only available for paid members
- Date of Judgement/Order
- Only available for paid members
- Related Assessment Year
- 24/09/2025
- Courts
- All ITAT, ITAT Delhi
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Threepence Craft Vs CIT/ITO (ITAT Delhi)
Trade Discount Not Commission- AO Made Enquiry, CIT Only Disagreed -CIT Cannot Substitute AO’s View:- ITAT Delhi Quashes 263 Order & Consequential Reassessment
Assessee filed appeal against revisionary order u/s 263 passed by CIT, & also against consequential assessment order u/s 143(3) r.w.s. 263 confirmed by CIT(A).
The dispute arose from CIT’s revision on ground that AO had not examined applicability of TDS u/s 195 on 12% discount allowed to overseas buyer, which was treated by CIT as commission liable for deduction of ...
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