In the ITAT Jaipur case, the issue revolved around a revision ...
ITAT Jaipur held that AO conducted adequate inquiries on salary payments to specified persons. PCIT's revision u/s 263 based on incorrect inference from AY 2017-18 not justified. Order quashed, appeal allowed.
May 21, 2024
Case Laws Income Tax AT
In the ITAT Jaipur case, the issue revolved around a revision u/s 263 by CIT concerning the assessee's case under limited scrutiny u/s 143(3). The primary focus was on payments to specified persons and a percentage disallowance on salary payments. The tribunal held that the AO had conducted inquiries and verified details submitted by the assessee, allowing the salary payments. The observations by the PCIT were based on a different assessment year, and a disallowance in one year cannot be the basis for doubting claims in another year. The tribunal concluded that the revision proceedings by the PCIT were beyond jurisdiction and against legal principles, quashing the order u/s 263 and allowing the assessee's appeal.
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