Trade Discount Not Commission: ITAT Quashes CIT’s Section 263 Revision for Overreach

Threepence Craft Vs CIT/ITO (ITAT Delhi) Trade Discount Not Commission- AO Made Enquiry, CIT Only Disagreed -CIT Cannot Substitute AO’s View:-  ITAT Delhi Quashes 263 Order & Consequential Reassessment Assessee filed appeal against revisionary order u/s 263 passed by CIT, & also against consequential assessment order u/s 143(3) r.w.s. 263 confirmed by CIT(A). The dispute arose from CIT’s revision on ground that AO had not examined applicability of TDS u/s 195 on 12% discount allowed to overseas buyer, which was treated by CIT as commission liable for deduction of tax. CIT further ...