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3 orders · Page 1 of 1
The Tribunal held that the PCIT's revisionary power under Section 263 was wrongly invoked as the AO had already examined the issue and accepted the assessee's claim based on submitted evidence. A mere change of opinion by the PCIT does not render the AO's order erroneous and prejudicial to revenue.
The Tribunal held that the addition for cash deposits during demonetization was unjustified, as family savings could explain the deposits. It also found the AO's method of estimating unaccounted sales by comparing bank deposits with disclosed sales to be erroneous.
The Tribunal held that the issue of whether interest earned by a partnership firm on deposits is includible for calculating partner remuneration is a debatable point. Therefore, it cannot be rectified under Section 154, which is meant for obvious and patent mistakes.