Sec 263 Quashed; AO Examined 10AA & R&D; Audit Objection Based Revision Invalid: ITAT Mumbai

Zensar Technologies Ltd. Vs PCIT (ITAT Mumbai)

Sec 263 Quashed – AO Made Detailed Enquiry on U/s 10AA & R&D Allocation -Revision Based on Audit Objection Held Invalid – ITAT Mumbai

The PCIT invoked revisionary powers u/s 263 alleging lack of enquiry by the AO regarding allocation of R&D expenses while allowing deduction u/s 10AA to SEZ units. ITAT noted that during original assessment, the AO issued multiple notices u/s 142(1) specifically examining R&D expenses and deduction claim, and the assessee furnished detailed replies with sup

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