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Income Tax - Highlights / Catch Notes

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The Appellate Tribunal addressed a case involving revision u/s ...


Revision u/s 263 initiated on ICDS grounds deemed unsustainable. AO's acceptance of assessee's explanation upheld.

Case Laws     Income Tax

June 6, 2024

The Appellate Tribunal addressed a case involving revision u/s 263 by PCIT questioning the recognition of liabilities 'Nardana Claim-1' and 'Nardana Claim-2' under ICDS. The Tribunal found that AO adequately investigated the issues through queries and responses from the assessee, rejecting PCIT's claim of lack of investigation. The Tribunal upheld the assessee's explanation that the liabilities were not recognized as income due to pending court disputes, following a court decision on income accrual. Citing Malabar Industries Co. Ltd., the Tribunal held that AO's view favoring the assessee was valid. PCIT's revision based on ICDS violations was deemed unsustainable, leading to the quashing of the revision order and restoration of the AO's assessment order. Assessee's appeal was allowed.

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