Reassessment was erroneous in absence of prima facie finding by CIT

CIT Vs Accel Limited (Madras High Court)

Conclusion: CIT to at least record a prima facie finding that certain amount claimed by assessee as deduction in its computation of income de facto related to earning of dividend income. Thus, it was held that in the absence of any such prima facie finding, the reassessment was erroneous and no addition could be made under section 14A.

Held: CIT on perusal of the assessment order observed

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