Revision u/s 263 justified as details not examined by AO: ITAT Mumbai

ICICI Bank Ltd Vs DCIT (ITAT Mumbai)

ITAT Mumbai held that non-examination of the details clearly makes the order of AO erroneous and prejudicial to the interest of revenue. Accordingly, PCIT correctly assumed the revisional jurisdiction under section 263 of the Income Tax Act.

Facts- Assessee is a company engaged in banking operations and related activities showing income from banking activities, dividends, interest on debentures, leasing, deposits and advances and commission fee etc.

AO passed the assessment order on 12/02/2019 u/s 143 (3) rws 144C (3) of the Act after making various additions/ disallowances. Thereafter, PCIT examined the records and held that the order of the learned Assessing Officer is erroneous and prejudicial to the interest of Revenue. Being aggrieved, the present appeal is filed.

Conclusion- Held that order of the learned PCIT does not show that what is the error in allowing the claim of the assessee wherein the amount is debited to the profit and loss account as write off .therefore, on this issue we do not find that there is any error in the order of the learned assessing officer in allowing the claim of the assessee which is after calling for the explanation and correctly allowed. Therefore, on the same issue of the bad debts allowed of Rs. 3,126,937,766/– the order of the learned PCIT is not sustainable.

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