Incorp Advisory Services Private Limited Vs PCIT (ITAT Mumbai)
This summary is based strictly on the provided content regarding the appeal filed by Incorp Advisory Services Private Limited against the order of the Principal Commissioner of Income-tax (PCIT), Mumbai-6, before the Income Tax Appellate Tribunal (ITAT), Mumbai, for the Assessment Year (A.Y.) 2020-21.
Background of the Case and Impugned Orders
The appeal challenged a revisional order passed by the Ld. PCIT under Section 263 of the Income-tax Act, 1961 (‘the Act’) on August 2, 2024. The PCIT’s order had set aside the original assessment order passed by the Assessment Unit under Section 143(3) read with Section 144B of the Act, dated September 6, 2022.
The assessee’s case was selected for limited scrutiny under the Computer-Assisted Scrutiny Selection (CASS) system. The specific purpose of the scrutiny was to verify substantial additions or the introduction of intangible assets during the relevant financial year, specifically to examine whether the assessee had inflated the value of these assets to claim higher depreciation and to verify the source of the investment. The assessee had acquired three units via a slump sale during the year.
PCIT’s Revisional Order under Section 263
The original assessment order accepted the claimed depreciation. However, the Ld. PCIT later reviewed the records and found that the claim of excess depreciation of $\text{Rs. 7,67,69,973}$ on intangible assets had not been duly verified by the Assessing Officer (AO) during the limited scrutiny.
