2023 (2) TMI 1340

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..... ssue of loss/expenditure incurred in respect of newly undertaken software product development project as capital loss/expenditure was not touched by the assessing officer in the reassessment proceedings u/s 147 of the Act. Therefore, Tribunal found that the CIT(A) was not justified in invoking the provisions of Section 263 on an issue which was not the subject-matter of the reassessment of the pro .....

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..... hether on the facts and in the circumstances of the case the Income Tax Appellate Tribunal substantially erred in law on holding that the Commissioner of Income Tax could not invoke the provisions of Section 263 in respect of the capital expenditure of Rs. 1,60,75,000/-? 3. We have heard Mr. Amit Sharma, learned counsel for the appellant/revenue. 4. The short issue involved in the instant case is .....

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