GIRNAR SOFTWARE PRIVATE LIMITED,6TH FLOOR, JAIPUR TEXTILE MARKET, B-2, NEAR MODEL TOWN, MALVIYA NAGAR, JAIPUR vs. PCIT – 2, JAIPUR, NEW CENTRAL REVENUE BUILDING

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ITA 330/JPR/2023Status: DisposedITAT Jaipur28 August 2023AY 2018-19Bench: HON’BLE SHRI SANDEEP GOSAIN, JM & HON’BLE SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)23 pages
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What did the Tribunal hold?

The Tribunal held that the assessment order could not be considered erroneous or prejudicial to the revenue's interest, especially when no exempt income was earned. Therefore, the PCIT was not justified in invoking Section 263 and directing the addition under Section 14A.

What were the facts?

The assessee company filed its return of income declaring a loss. The PCIT invoked Section 263, proposing to revise the assessment order to make an addition under Section 14A. The assessee contended that no exempt income was earned, thus Section 14A was not applicable.

What were the issues?

Whether the PCIT was justified in invoking Section 263 to direct an addition under Section 14A when the assessee had not earned any exempt income.

Which sections of the Income-tax Act were involved?

Section 263,Section 14A

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Income Tax Appellate Tribunal, JAIPUR BENCHES,”A” JAIPUR

Before: HON’BLE SHRI SANDEEP GOSAIN, JM &

For Appellant: Shri PC Parwal, CA jktLo dh vksj ls@
Hearing: 19/07/2023Pronounced: 28/08/2023

vkns'kkuqlkj@ By order,

सहायक पंजीकार@Aेेज. त्महपेजतंत

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