SC Upholds Section 263 Revision Due to Unreasoned Assessment Order

L G Electronics India Pvt. Ltd. Vs PCIT (Supreme Court of India) The dispute concerned the exercise of revisional jurisdiction under Section 263(1) of the Income-tax Act in relation to the assessee’s claim that a subsidy of ₹49,38,00,503 received under a Government of Maharashtra scheme constituted a capital receipt not chargeable to tax. Under the scheme, the assessee was permitted to collect sales tax and later claim refund up to 75% of the gross fixed capital investment. The Assessing Officer (AO) accepted the assessee’s treatment of the subsidy as a capital receipt without an...