S. 263 CIT can revise Assessment Order to make Disallowance U/s. 14A if AO fails to do so

HIGH COURT OF CALCUTTA Commissioner of Income-tax-III, Kolkata versus RKBK Fiscal Services (P.) Ltd. IT Appeal No. 389 of 2007 Date of Pronouncement – 19.02.2013 JUDGMENT Girish Chandra Gupta, J. This appeal preferred by the Revenue is directed against a judgment and order dated 28th February, 2007 by which the order of the C.I.T. dated 4th September, 2006 passed under Section 263 of the Income Tax Act of 1961 was reversed. The undisputed facts and circumstances of the case are as follows:- The assessee earned a sum of Rs. 2,85,08,419/- on account of dividend which is ...