Invocation of provisions of section 263 without satisfying twin condition is unsustainable

Manjri Stud Farm Pvt Ltd Vs ACIT (ITAT Mumbai) ITAT Mumbai held that invocation of provisions of section 263 of the Income Tax Act without satisfying the twin condition i.e. erroneous and prejudicial to the interest of revenue not satisfied. Hence, order passed u/s 263 set aside. Facts- Post completion of assessment, Pr.CIT invoked provisions of section 263. Pr.CIT mentioned that assessee has claimed deduction u/s. 24(b) of the Act of ₹.11,83,44,908/- and assessee has not furnished documentary evidences in support of its claim during the assessment proceedings. Further, he mentioned that on ...