AO's Acceptance of Interest Treatment in Original Assessment Cannot be Challenged After Section 263 Order Set Aside

ITAT quashed the addition made under s.143(3) read with s.263, as the underlying revision order by Pr. CIT under s.263 was previously set aside. The Tribunal found that AO had conducted proper inquiry regarding interest treatment during scrutiny assessment. The difference between Form 26AS and ITR amounts was explained by interest received from banks being adjusted against project expenditure in company's financial statements. The assessee's explanation was accepted by AO during original assessment. Since the foundational s.263 revision order was invalidated, the subsequent addition made pursuant to it could not sustain. ITAT vacated the addition and set aside CIT(A)'s order upholding it. .....

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