MAX FINANCIAL SERVICE LIMITED ,NAWANSHAHR vs. PRINCIPAL COMMISSIONER OF INCOME TAX -1, JALANDHAR
In the result, the appeal of the assessee is therefore partly allowed
ITA 121/ASR/2020[2015-16]Status: DisposedITAT Amritsar31 Mar 2021AY 2015-16
For Appellant: Shri Deepak ChopraFor Respondent: Smt.Prabhjot Kaur, CIT
Section 143(3)Section 263
deemed to be erroneous and prejudicial to the interest of the
Revenue. The said explanation has been interpreted in
10
A.Y.2015-16
various decisions of the ITAT holding that the explanation
cannot be resorted to simpliciter for giving a finding of
error, and the substantive requirements of section 263 ,as
stated above, have still to be fulfilled for applying the
explanation
