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Revisionary proceedings u/s. 263 resulting into second opinion/ view of PCIT impermissible: ITAT Ahmedabad
Case Law Details
- Case Name
- Black Rock Financial Services Pvt Ltd Vs PCIT (ITAT Ahmedabad)
- Appeal Number
- Only available for paid members
- Date of Judgement/Order
- Only available for paid members
- Related Assessment Year
- 2018-19
- Courts
- All ITAT, ITAT Ahmedabad
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Black Rock Financial Services Pvt Ltd Vs PCIT (ITAT Ahmedabad)
ITAT Ahmedabad held that invocation of provisions of section 263 of the Income Tax Act by PCIT impermissible as exercise of such provisions amounts to second opinion/ view which is unsustainable in law.
Facts- PCIT observed that the assessee accepted short term borrowing of Rs.1,72,76,00,000/- from Fortune Broking Intermediary Pvt. Ltd. However, the assessee did not show any interest income in Profit & Loss Account and, therefore, the proportionate disallowance of interest expenditure should have been made u/s. 36(1)(iii) of th...
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