An Assessment attracts Section 263 revision if AO has not taken one of two possible views

Sanctuary Television Pvt. Limited Vs DCIT (ITAT Hyderabad) The PCIT holds that in this case administrative expenses were in the nature of pre-operative expenditure which could not be set-off against the assessee’s foregoing interest income. And that the Assessing Officer’s action allowing the assessee’s claim in a very casual and mechanical manner deserves to be revised for want of proper enquiry rendering the impugned assessment as both erroneous as well as prejudicial to interest of the Revenue. ITAT observed that assessee’s administrative expenses are in the nature of compulsorily o...