Section 263 order without appreciating facts in true perspective is not sustainable

R.P. Polypacks Pvt. Limited Vs DCIT (ITAT Kolkata)

In brief, the issue according to the ld. Commissioner is that the assessee had made provision of Excise Duty, which was not an allowable expenditure and ld. Assessing Officer has erred in accepting this claim of the assessee in an assessment order passed under section 143(3) of the Income Tax Act. On the other hand, it has been demonstrated before us that though a provision of Rs.27,14,588/- was made by the assesese, which is reflecting in account as on 31.03.2013 but before

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