UBS BUSINESS SOLUTIONS (INDIA) PRIVATE LIMITED (SUCCESSOR TO CREDIT SUISSE SERVICES (INDIA) PVT LTD),PUNE vs. PCIT, PUNE - 1, PUNE, MAHARASHTRA

ITA 1407/PUN/2025Status: DisposedITAT Pune28 November 2025AY 2020-21Bench: MS.ASTHA CHANDRA, JUDICIAL MEMBER AND DR.DIPAK P. RIPOTE (Accountant Member)1 pages
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What did the Tribunal hold?

The Tribunal held that the assessment order was not erroneous or prejudicial to the revenue because the assessee's entire expenditure, including repairs and maintenance, was recovered from associated enterprises with a markup. Therefore, the twin conditions for invoking Section 263 were not met.

What were the facts?

The Principal Commissioner of Income Tax (PCIT) initiated proceedings under Section 263 of the Income Tax Act, 1961, to revise an assessment order. The PCIT believed the Assessing Officer (AO) had not adequately verified repairs and maintenance expenditure and that certain computer peripherals should have been capitalized.

What were the issues?

Whether the PCIT's revision order under Section 263 was justified when the assessee recovered all expenses with a markup from associated enterprises, and whether the AO's verification of repairs and maintenance expenses was sufficient.

Which sections of the Income-tax Act were involved?

Section 263,Section 143(3),Section 144B

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Income Tax Appellate Tribunal, PUNE BENCHES “B” :: PUNE

Before: MS.ASTHA CHANDRA & DR.DIPAK P. RIPOTE

For Appellant: Shri Rajendra Agiwal - AR
For Respondent: Shri Amit Bobde – CIT(DR)
Hearing: 23/09/2025Pronounced: 28/11/2025

PER DR. DIPAK P. RIPOTE, AM: This appeal is filed by the Assessee against the order of ld.Principal Commissioner of Income Tax, Pune-1 passed under section 263 of the Income Tax Act, 1961 for A.Y.2020-21, dated 31.03.2025 emanating from Assessment Order u/s.143(3) r.w.s 144B

ITA No.1224/PUN/2025 [A]

of the Income Tax Act, 1961 dated 06.09.2022. The Assessee has raised following grounds of appeal : “General Ground Grounds of

The order continues below.

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