The case pertains to rectification u/s 154 and the power of the ...

Assessing Officer's Scrutiny Powers Limited; ITAT Upholds CIT(A)/NFAC's Decision on Non-Rectifiable Debatable Issues.

November 5, 2024

Case Laws Income Tax AT

The case pertains to rectification u/s 154 and the power of the Assessing Officer (AO) to travel beyond the reasons for which the case was selected for scrutiny. The key points are: 1) The case was selected for limited scrutiny under CASS for verification of interest expenses and unsecured loans. 2) The AO asked for details of preliminary expenses, which the assessee provided, and the AO accepted. 3) The CIT(A)/NFAC correctly held that a debatable issue cannot be subject matter of rectification u/s 154, as it is not an apparent mistake. 4) The AO did not make any addition regarding preliminary expenses, despite asking for details. 5) Since no addition was made other than the reasons for which the case was selected for scrutiny, the assessee cannot raise any ground on this issue. Consequently, the ITAT upheld the CIT(A)/NFAC's order and dismissed the Revenue's grounds, while also dismissing the assessee's grounds.

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The case pertains to rectification u/s 154 and the power of the ...

Assessing Officer's Scrutiny Powers Limited; ITAT Upholds CIT(A)/NFAC's Decision on Non-Rectifiable Debatable Issues.

November 5, 2024

Case Laws Income Tax AT

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