“erroneous and prejudicial”

Rectification & RevisionSection 263Section 2633,136 judgments

The decision most relied on for erroneous and prejudicial is Malabar Industrial Co. Ltd. v. CIT (243 ITR 83), cited in 2,943 judgments on BharatTax.

Leading authorities on erroneous and prejudicial

Malabar Industrial Co. Ltd. v. CIT

243 ITR 83 · 2000 · Supreme Court

2,943

citing judgments

For revision under Section 263, the Assessing Officer's order must be both erroneous and prejudicial to the interests of the revenue; if either condition is not met, the revisionary jurisdiction cannot be invoked. An order is not erroneous merely because the Assessing Officer did not record the details of enquiries conducted, provided due enquiries were made.

CIT v. Max India Ltd.

295 ITR 282 · 2007 · Supreme Court

1,162

citing judgments

Under Section 263, an assessment order is not erroneous and prejudicial to the interest of the revenue merely because the Principal Commissioner disagrees with the Assessing Officer's (AO) view, particularly if the AO has adopted one of two permissible views in law, unless that view is completely unsustainable. If due inquiries were made, the AO's order does not become erroneous solely because the fact of inquiries was not recorded.

CIT v. Gabriel India Ltd.

203 ITR 108 · 1993 · High Court

990

citing judgments

The Commissioner cannot revise an assessment order under Section 263 merely because they hold a different opinion or believe a deeper inquiry was warranted if the Assessing Officer has applied their mind and conducted some inquiry. Revision under Section 263 is permissible only in cases of a complete lack of inquiry or non-application of mind by the Assessing Officer, not for merely inadequate inquiry.

CIT v. Sunbeam Auto Ltd.

332 ITR 167 · 2011 · High Court

897

citing judgments

The Commissioner cannot revise an assessment under Section 263 merely because the assessment order does not explicitly reflect an inquiry, or because the Commissioner holds a different opinion. An inquiry, even if considered inadequate, or an assessment based on a plausible view by the Assessing Officer after due examination, does not automatically make the order erroneous or prejudicial to the interests of the revenue.

Rampyari Devi Saraogi v. CIT

67 ITR 84 · 1968 · Supreme Court

616

citing judgments

An assessment order is erroneous and prejudicial to the Revenue's interests if the Assessing Officer accepts a sum offered as income by an assessee, even when that sum was not actually earned, thereby allowing revision under Section 263.

Gee Vee Enterprises v. Addl. CIT

99 ITR 375 · 1975 · High Court

543

citing judgments

An assessment order is erroneous and prejudicial to the interest of revenue if the Assessing Officer fails to make proper inquiries before accepting the assessee's statements or claims. The Commissioner can revise such an order under Section 263 without conducting further inquiries himself.

ITO v. D.G. Housing Projects Ltd.

343 ITR 329 · 2012 · High Court

438

citing judgments

For exercising revisional jurisdiction under Section 263, the Commissioner must first find that the Assessing Officer's order is erroneous and unsustainable in law, as this is a condition precedent. An order is not erroneous merely because two views are possible, or if the Commissioner disagrees with the Assessing Officer's permissible view, or to simply remit the matter for further enquiries.

CIT v. Vikas Polymers

341 ITR 537 · 2012 · High Court

318

citing judgments

An assessment order is not erroneous and prejudicial under Section 263 merely because the Assessing Officer did not record an enquiry and its satisfactory answer in the assessment order, provided such an enquiry was conducted. For revision under Section 263, the Commissioner must also provide the assessee an opportunity of being heard and examine their explanation.

Judgments citing erroneous and prejudicial

M/S. Thirumagal Alloys Pvt. Ltd., Dharmapuri vs. ACIT, Circle-1, Hosur

In the result, both the appeals filed by the assessee are dismissed

ITA 3243/CHNY/2019[2013-14]Status: DisposedITAT Chennai12 Oct 2022AY 2013-14

Bench: Shri V. Durga Rao & Shri Manoj Kumar Aggarwalआयकर अपील सं./I.T.A. No. 2913/Chny/2018 िनधा"रण वष"/Assessment Year:2013-14 M/S. Thirumagal Alloys Pvt Ltd., Vs. The Principal Commissioner Of No. 5/95, Cmelbatchhapet, Income Tax, Salem. Sennimalai Gardens, Harur, Tamil Nadu 636 903. [Pan:Aabck1431D] (अपीलाथ"/Appellant) (""थ"/Respondent) आयकर अपील सं./I.T.A. No.3243/Chny/2019 िनधा"रण वष"/Assessment Year:2013-14 M/S. Thirumagal Alloys Pvt Ltd., Vs. The Assistant Commissioner Of No. 5/95, Cmelbatchhapet, Income Tax, Sennimalai Gardens, Harur, Circle I, Salem. Tamil Nadu 636 903. (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri T. Vasudevan, Advocate ""थ" की ओर से/Respondent By : Shri M. Murali, Cit सुनवाई की तारीख/ Date Of Hearing : 21.09.2022 घोषणा की तारीख /Date Of Pronouncement : 12.10.2022 आदेश /O R D E R Per V. Durga Rao,: Both The Appeals Filed By The Assessee Are Directed Against Different Orders Of The Ld. Principal Commissioner Of Income Tax, Salem, Dated 01.03.2018 Passed Under Section 263 Of The Income Tax Act, 1961

For Appellant: Shri T. Vasudevan, AdvocateFor Respondent: Shri M. Murali, CIT

Section 139(1)Section 142(1)Section 143(1)Section 143(2)Section 143(3)Section 263

Assessing Officer under section 143(3) of the Act dated 15.03.2015 for the assessment year 2013-14 was found to be erroneous and prejudicial to the interest of the Revenue and called the assessee to explain. One of the Directors of the assessee company Shri Vijay, K.S. appeared before ... under section 143(3) of the Act, examined all the details and therefore, the order passed by the ld. PCIT is neither erroneous nor prejudicial to the interest or the Revenue. 5. On the other hand, the ld. DR strongly supported the order passed by the ld. PCIT and submitted

Trivitron Health Care Pvt. Ltd., Chennai vs. DCIT, Chennai

In the result, the appeal filed by the assessee is allowed

ITA 1340/CHNY/2019[2014-15]Status: DisposedITAT Chennai12 Oct 2022AY 2014-15

Bench: Shri Mahavir Singh, Hon’Ble & Shri G. Manjunatha, Hon’Bleआयकर अपील सं./Ita No.1340/Chny/2019 िनधा"रण वष" /Assessment Year: 2014-15 V. M/S.Trivitron Healthcare Pvt. Ltd., The Dy. Commissioner- “Sapthagiri Bhavan”, Of Income Tax, New No.15, Old No.25, Corporate Circle-3(1), Trivitron Sapthagiri Bhawan, Chennai. 4Th Street, Abhiramapuram, Chennai. [Pan: Aaact 9378 H] (अपीलाथ"/Appellant) (""यथ"/Respondent)

For Respondent: Mr.M.Rajan, CIT

Section 119Section 143Section 143(3)Section 263Section 36(1)(va)

commissioner can issue notice only if he / she comes to the conclusion that the order passed by the AO is considered as erroneous and prejudicial to the interest of revenue, where AO passed order:-. 1) without making any inquiries/verification which he/she is required to make. 2) without making inquiry into ... against the assessee or any other personal and AO passed their order without considering such judgment then such order shall be considered as erroneous and prejudicial to the interest of revenue. The Appellant respectfully submit that AO had called for all the records and documents in connection with the assessment

Thirumagal Alloys Pvt. Ltd., Harur vs. ACIT Circle 1, Hosur

In the result, both the appeals filed by the assessee are dismissed

ITA 2913/CHNY/2018[2013-14]Status: DisposedITAT Chennai12 Oct 2022AY 2013-14

For Appellant: Shri T. Vasudevan, AdvocateFor Respondent: Shri M. Murali, CIT

Section 139(1)Section 142(1)Section 143(1)Section 143(2)Section 143(3)Section 263

Fdc Limited, Mumbai vs. Naresh Kumar Balodia Pr -CIT -1, Mumbai

In the result, the order under Section 263 of the Act passed by the learned PCIT on 22ndMarch 2022 for A

ITA 742/MUM/2022[2016-17]Status: DisposedITAT Mumbai12 Oct 2022AY 2016-17

Bench: Shri Prashant Maharishi, Am & Shrirahul Chaudhary, Jm Pr. Commissioner Of Fdc Limited Income Tax–I, Fdc Limited 142–148, Room No. 330, Fdc Limited 3Rd Floor, Aayakar Bhavan S.V. Road, Vs. Jogeshwari (West), Mk Road Mumbai 400102 Mumbai-400 020 (Respondent) (Appellant) Pan No.Aaacf0253H Assessee By : Shri K Shivaram & Shri Rahul Hakani, Ars Revenue By : Shri Manoj Kumar, Cit Dr Date Of Hearing: 20.07.2022 Date Of Pronouncement: 12.10.2022

For Appellant: Shri K Shivaram &For Respondent: Shri Manoj Kumar, CIT DR

Section 143(3)Section 144CSection 263Section 35Section 35(1)(iv)

Mumbai [ The Ld AO ] under Section 143(3) read with section 144C of the Act dated 19th February, 2020 is erroneous and prejudicial to the interest of the Revenue. FDC Limited; A.Y. 2016–17 02. The brief fact of the case shows that assessee is a company engaged ... these two letters, the learned Assessing Officer granted deduction. Therefore, the order passed by the learned Assessing Officer was claimed to be not erroneous or prejudicial to the interest of the Revenue. 04. The learned PCIT rejected the contention of the assessee because assessee has claimed deduction under Section

Tuscan Ventures Pvt.Ltd, Mumbai vs. ACIT Cir, Mumbai

In the result, the appeal of the assessee is allowed

ITA 1394/MUM/2022[2017-18]Status: DisposedITAT Mumbai03 Oct 2022AY 2017-18

Bench: Shri Amarjit Singh & Shri Sandeep Singh Karhailtuscan Ventures Private Vs. Acit, Circle 5(3)(2) Limited, 11, Silver Arch, 5Th Floor, 573, Aayakar Napeansea Road, Bhavan, M.K. Road, Mumbai – 400006 Mumbai - 400020 स्थायी लेखा सं./जीआइआर सं./ Pan/Gir No: Aacct7474J Appellant .. Respondent

For Appellant: Hiro RaiFor Respondent: A.B.Koli

Section 142(1)Section 143(2)Section 143(3)Section 14ASection 263

mandatory and therefore the method of disallowance followed by the assessee company and accepted by AO has made the assessment order erroneous and prejudicial to the interest of the revenue. 4. The learned Principal Commissioner of Income Tax erred in concluding that the assessment had been completed without proper application

Ashokkumar Bhanwarlal Chhajer, Sanpada vs. Pr. CIT - (Central), Pune

In the result, the appeal filed by the assessee is allowed

ITA 1361/MUM/2022[2017-18]Status: DisposedITAT Mumbai30 Sept 2022AY 2017-18

Section 142(1)Section 143(3)Section 263Section 263(1)

that the AO has passed the assessment order after examining those details and hence the said assessment order cannot be considered to be erroneous and prejudicial to the interests of revenue. 4. The Ld PCIT was not convinced with the explanations given by the assessee. He held that the assessing ... possible and the Income-tax Officer has taken one view with which the Commissioner does not agree, it cannot be treated as an erroneous order prejudicial to the interests of the Revenue unless the view taken by the Income-tax Officer is unsustainable in law.” The principle which has been

Shapoorji Pallonji and Company Private Limited, Mumbai vs. Principle Commissioner of Income Tax (Central), -4, Mumbai

In the result, the appeal of the assessee is allowed

ITA 1149/MUM/2022[2012-13]Status: DisposedITAT Mumbai30 Sept 2022AY 2012-13

Section 115JSection 142(1)Section 143(2)Section 143(3)Section 148Section 14ASection 263Section 92C

section 263 dated 30/03/2022 by holding the order dated 09/12/2019 passed under section 143(3) read with section 147 of the Act as erroneous and prejudicial to the interest of the revenue and directing the ld. AO to complete assessment afresh. 3.7. At the outset, we find that in response ... which is the subject matter of present revision proceedings before us u/s.263 of the Act), the said assessment order dated 20/04/2016 would become erroneous and prejudicial to the interest of the revenue 6 M/s. Shapoorji Pallonji and Company Pvt. Ltd., warranting revision u/s.263 of the Act by the ld. PCIT

The Deutsche Investments India P.Ltd, Mumbai vs. Pr CIT 12, Mumbai

In the result, appeal of the assessee is allowed

ITA 3169/MUM/2017[2011-12]Status: DisposedITAT Mumbai30 Sept 2022AY 2011-12

Section 143(3)Section 263Section 92C

Accordingly, a notice dated 02.03.2016 was issued to the assessee to explain as to why the assessment order may not be considered as erroneous and prejudicial to the interest of the revenue and why section 263 proceedings cannot be invoked. 4. In response, assessee filed its submission vide letter dated ... passing an order under section 263 of the Act on the grounds that the original assessment order passed under section 143(3) was erroneous and prejudicial to the interest of the revenue and directing AO to frame fresh assessment order (de novo) after giving reasonable opportunity of hearing

L & T Infra Debt Fund Ltd., Mumbai vs. CIT (Exemption), Mumbai

In the result, appeal filed by the assessee is dismissed

ITA 809/MUM/2021[2016-17]Status: DisposedITAT Mumbai29 Sept 2022AY 2016-17

Section 10(47)Section 148Section 148ASection 263

without examining this important aspect. Accordingly, the learned CIT(E) took the view that the assessment order passed by the Assessing Officer is erroneous and prejudicial to the interest of Revenue. Accordingly he initiated revision proceedings under section 263 of the Act. After hearing the assessee, learned ... possible and the Income-tax Officer has taken one view with which the Commissioner does not agree, it cannot be treated as an erroneous order prejudicial to the interests of the Revenue unless the view taken by the Income-tax Officer is unsustainable in law.” The principle which has been

Smt. Nayna I. Mantri, Mumbai vs. Pr. CIT-30, Mumbai

In the result, appeal of the assessee is allowed

ITA 1982/MUM/2021[2012-13]Status: DisposedITAT Mumbai29 Sept 2022AY 2012-13

Bench: Shri Baskaran Br& Shri Pavan Kumar Gadalesmt. Nayna I. Mantri, Vs. Principal Commissioner 1601, Daffodil Tower, Of Income Tax-30, Nr. Chinchpoli Fatak, 540, 5Th Flr. Kautilya S.V. Road, Malad West, Bhavan, C-41 To C-43, Mumbai-400064 G Block, Bkc, Bandra East, Mumbai-400051 Pan No.Aaopm2589C Appellant Respondent

Section 10(38)Section 143(3)Section 148Section 263

disputed the fact that the Assessee has actually spent the said amount and hence the assessment order sought to be revised is neither erroneous nor prejudicial to the interests of the revenue and could not be revised. 4 ITA No.1982/MUM/2021.Nayna I Mantri.Mumbai 2. The appellant craves leave to add, amend ... observations the Pr,CIT was not satisfied with the order passed under Section 143(3) r.w.s. 147 of the Act as it is erroneous and prejudicial to the interest of the revenue and directed the AO to frame assessment de nova after providing adequate opportunity of hearing to the assessee

Siemens Ltd, Mumbai vs. DCIT 7(2), Mumbai

In the result, appeal of the assessee for A

ITA 4354/MUM/2010[2003-04]Status: DisposedITAT Mumbai29 Sept 2022AY 2003-04

Bench: Us, The Effective Issue To Be Decided In These Appeals Is As To Whether The Ld. Administrative Cit (Ld. Cit) Was Justified In Invoking Revisionary Jurisdiction U/S.263 Of The Act In The Facts & Circumstances Of The Instant Case By Treating The Order Of The Ld. Ao As Erroneous In As Much As It Is Prejudicial To The Interest Of The Revenue.

Section 143(2)Section 143(3)Section 245CSection 245D(1)Section 245D(3)Section 245D(4)Section 263

Commission. Hence, an order passed by the ld. AO as per the directions of the Hon’ble Settlement Commission cannot be construed as erroneous and prejudicial to the interest of the Revenue warranting revision jurisdiction u/s.263 of the Act by the ld. CIT. Hence, the revision jurisdiction u/s.263

Siemens Ltd, Mumbai vs. DCIT 7(2), Mumbai

In the result, appeal of the assessee for A

ITA 4353/MUM/2010[2002-03]Status: DisposedITAT Mumbai29 Sept 2022AY 2002-03

Section 143(2)Section 143(3)Section 245CSection 245D(1)Section 245D(3)Section 245D(4)Section 263

Siemens Ltd, Mumbai vs. DCIT 7(2), Mumbai

In the result, appeal of the assessee for A

ITA 4352/MUM/2010[2001-02]Status: DisposedITAT Mumbai29 Sept 2022AY 2001-02

Section 143(2)Section 143(3)Section 245CSection 245D(1)Section 245D(3)Section 245D(4)Section 263

M/S. Karnataka State Beverages Corporation Limited, Bangalore vs. The Principal Commissioner of Income Tax, Bangalore - 4, Bangalore

In the result, the appeal filed by the assessee stands partly allowed

ITA 397/BANG/2020[2015-16]Status: DisposedITAT Bangalore29 Sept 2022AY 2015-16

For Respondent: Shri Narendra Sharma

Section 143(3)Section 154Section 263

justified in law in setting aside assessment order passed u/s 143(3) of the Act by holding that the assessment order is erroneous and prejudicial to the interest of revenue on the facts and circumstances of the case. 7. The learned Pr. Commissioner of Income Tax failed to appreciate that ... noticed that the assessment concluded by the Ld.DCIT, Circle – 4(1)(1) for A.Y. 2015-16 u/s. 143(3) of the Act is erroneous and prejudicial to the interest of revenue. 2.3 The Ld.PCIT issued notice u/s. 263 on 26/06/2019. The scanned copy of the same is reproduced hereunder. Page

V.M. *& Co., Ramanathapuram vs. DCIT Circle 1, Karaikudi

The appeal stands allowed in terms of our above order

ITA 2267/CHNY/2018[2015-16]Status: DisposedITAT Chennai28 Sept 2022AY 2015-16

Bench: Hon’Ble Shri Mahavir Singh & Hon’Ble Shri Manoj Kumar Aggarwal, Am

For Appellant: Shri R. Meenakshi Sundaram (Advocate)-Ld. ARFor Respondent: Shri M. Rajan (CIT) – Ld. DR

Section 143(3)Section 263

submitted that proper enquiries were made by Ld. AO before framing the assessment and the order could not be held to be erroneous or prejudicial to the interest of the revenue. The Ld. CIT-DR on the other hand, justified the revisional proceedings on the ground that the issues flagged ... income at Rs.131.35 Lacs. Revisional Proceedings 5. Subsequently, Ld. Pr. CIT, upon perusal of case records, held an opinion that the order was erroneous and prejudicial to the interest of the revenue and accordingly, show-caused the assessee on 16.05.2018. The same stem from the observation

Nepal Singh Rathod (HUF), Hubli vs. Principal Commissioner of Income Tax, Hubli

In the result, the appeal filed by the assessee is allowed

ITA 400/BANG/2022[2017-18]Status: DisposedITAT Bangalore28 Sept 2022AY 2017-18

Bench: Shri N.V. Vasudevan & Shri Chandra Poojariassessment Year: 2017-18

For Appellant: Shri K.R. Pradeep &For Respondent: Shri Sumer Singh Meena, D.R

Section 142(1)Section 143(2)Section 143(3)Section 263

u/s.263 and consequent proceedings are bad in law and without jurisdiction. 7. That the CIT erred in holding that order of assessment was erroneous and prejudicial to the interests of revenue. 8. That the CIT erred in giving a finding that the AO had not examined details of cash deposit ... also points to the same direction. They have held that orders, which are subversive of the administration of revenue, must be regarded as erroneous and prejudicial to the interests of the revenue. If the Assessing Officers are allowed to make assessments in an arbitrary manner, as has been done

Lions Club of Malad Borivali Charity Trust, Mumbai vs. CIT Exemptions, Mumbai

In the result, the appeal filed by the assessee is dismissed

ITA 1458/MUM/2022[2017-18]Status: DisposedITAT Mumbai27 Sept 2022AY 2017-18

Bench: Shri Kuldip Singh () & Shri Om Prakash Kant () Assessment Year: 2017-18 Lions Club Of Malad Borivali Cit Exemptions, Charity Trust, 601,6Th Floor, Cumballa Hills, Pd Lions College, Sv Road, Vs. Mumbai-400026. Sunder Nagar, Malad West, Mumbai-400064. Pan No. Aaatl 1407 C Appellant Respondent Assessee By : Mr. Shankarlal Jain, Ar Revenue By : Ms. Shailja Rai, Cit-Dr Date Of Hearing : 24/08/2022 Date Of Pronouncement : 27/09/2022

For Appellant: Mr. Shankarlal Jain, ARFor Respondent: Ms. Shailja Rai, CIT-DR

assessment order as passed as erroneous and holding the assessment order as passed as erroneous and holding the assessment order as passed as erroneous and prejudicial to the interest of the revenue, without properly prejudicial to the interest of the revenue, without properly prejudicial to the interest of the revenue ... assessment the finding of the Ld. CIT(E) holding the assessment the finding of the Ld. CIT(E) holding the assessment order as erroneous and prejudicial to the interest of the Revenue. erroneous and prejudicial to the interest of the Revenue. erroneous and prejudicial to the interest of the Revenue

Sasanur Hospital, Vijaypur vs. Principal Commissioner of Income Tax, Hubli

In the result, the appeal filed by assessee as well as the appeal of revenue stands allowed for statistical purposes

ITA 415/BANG/2022[2017-18]Status: DisposedITAT Bangalore27 Sept 2022AY 2017-18

Bench: Smt. Beena Pillai & Shri Laxmi Prasad Sahuassessment Year : 2017-18

For Appellant: Shri Ashok Mandur, C.A by RevenueFor Respondent: Shri Vilas Shinde, CIT (DR) by

Section 142(1)Section 143(3)Section 263Section 36(1)(va)

Bang) 4. After discussing in detail in his order, he observed that the order passed by the AO is erroneous and prejudicial to the interest Page 4 of 10 of the Revenue, accordingly he directed the AO to make fresh assessment in accordance with law and it was also directed ... carried out any enquiry in respect of the points pointed out by the ld.Pr.CIT. Therefore, the order passed by the AO is erroneous and prejudicial to the interest of the revenue. After discussing in detail, the ld.Pr.CIT directed the AO to make fresh assessment in accordance with

Laxmina Ventures, Vashi vs. Pr. CIT -28, Navi Mumbai

In the result, the appeal filed by the assessee is dismissed

ITA 1254/MUM/2021[2015-16]Status: DisposedITAT Mumbai26 Sept 2022AY 2015-16

Bench: Shri Baskaran Br& Shri Pavan Kumar Gadalelaxmina Ventures, Vs. Principal Commissioner 103, Vardhmanmarket, Of Income Tax,3 Rd Floor, Opp: Andhra Bank I T Department, Vashi Sector-17,Vashi, Railway Station, Navi Mumbai-400703 Commercial Complex, Navimumbai-400703 Pan No.Aaefl3415G Appellant Respondent

Section 143(1)Section 143(2)Section 143(3)Section 263Section 43C

verify the receipts from the prospective buyers are before the date of agreement and observed that the order passed by the A.O. is erroneous and prejudicial to the interest of the revenue and issued notice under Section 263 of the Act. In-compliance to notice ... applicability of Section 43CA of the Act.The Pr.CIT is of the opinion that the assesseement order passed U/sec143(3) of the Act is erroneous and prejudicial to the interest of Revenue and invoked the explanation 2 sub section 1 of 263 of the Act and has set-aside the assesseement

Skf Engineering & Lubrication India Private Limited, Bangalore vs. Joint Commissioner of Income Tax, Circle-4(1)(1), Bangalore

In the result, the appeal filed by the assessee is allowed

ITA 534/BANG/2022[2012-13]Status: DisposedITAT Bangalore26 Sept 2022AY 2012-13

Bench: Shri George George K. & Ms. Padmavathy S.Skf Engineering & Lubrication Vs. Jcit, Circle - 4(1)(1) India Pvt. Ltd. Bmtc Building (Formerly Lincoln Helios (India) Ltd & 80 Feed Road, 6Th Block, Skf Engineering & Lubrication India Ltd Koramangala No.249/250, Bommasandra Bengaluru 560095 Indl. Area, Phase 3, Hosur Road Bengaluru 560099 Pan – Aaacl2061P (Appellant) (Respondent) Assessee By: Shri Deepak Chopra, Ca Revenue By: Smt. Priyadarshini Baseganni, Addl. Cit

For Appellant: Shri Deepak Chopra, CAFor Respondent: Smt. Priyadarshini Baseganni, Addl. CIT

Section 143Section 143(3)Section 263

issued by the PCIT stating that the order under Section 143(3) r.w.s. 144C(13) of the Act dated 16.02.2016 is erroneous and prejudicial to the interest of Revenue because the assessee has been allowed deduction for provision for liquidated damages on Rs.49,20,000/- which was an unascertained liability