EATON TECHNOLOGIES PRIVATE LIMITED,PUNE vs. PRINCIPAL COMMISSIONER OF INCOME TAX, PUNE

ITA 1160/PUN/2024Status: HeardITAT Pune03 March 2025AY 2017-18Bench: SHRI R.K. PANDA (Vice President), MS. ASTHA CHANDRA (Judicial Member)1 pages
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What did the Tribunal hold?

The Tribunal held that the PCIT was not justified in assuming jurisdiction under Section 263 because the twin conditions of the order being erroneous and prejudicial to the revenue were not cumulatively satisfied. The AO's actions were found to be in line with Tribunal and High Court decisions.

What were the facts?

The Principal Commissioner of Income Tax (PCIT) initiated revision proceedings under Section 263 against the assessee's assessment order. The PCIT believed the Assessing Officer (AO) erred by allowing a deduction under Section 10AA and by not considering a disallowance under Section 14A while computing the final income.

What were the issues?

Whether the PCIT was justified in invoking Section 263 when the AO's order was not erroneous, despite potentially being prejudicial to revenue, and whether the AO correctly applied Section 10AA and Section 14A based on existing precedents.

Which sections of the Income-tax Act were involved?

Section 263,Section 10AA,Section 14A

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Income Tax Appellate Tribunal, “A” BENCH, PUNE

Before: SHRI R.K. PANDA & MS. ASTHA CHANDRA

For Appellant: Smt. Vishal Kalra
Hearing: 27.02.2025Pronounced: 03.03.2025

PER R.K. PANDA, VICE PRESIDENT :

This appeal filed by the assesseee is directed against the order dated 23.03.2024 passed u/s.263 of the Income- tax Act, 1961 by the Principal Commissioner of Income Tax, Pune -1 (in short ‘PCIT) for the Assessment Year 2017-18. 2. Facts of the case, in brief, are that the assessee is a Private Limited company engaged in the business of providing engineering design development, software development, back office support and business development services. The assessee filed its return of income for the A.Y. 20

The order continues below.

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