(Now known as Sony India Limited)

263 of the Act was passed. 49. There is an additional reason why the assessee‘s contentions must fail. In the present case, the claim of the assessee is that they had disclosed the international transaction in their report under Section 92E which included AMP expenses incurred by them. This aspect relates to merits, i.e. whether or not there

VAKSONS METAPLAST PVT LTD,DELHI vs. PCIT(CENTRAL), DELHI

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

Bench: Shris.Rifaur Rahman & Shri Anubhav Sharma

1) (a) where Officer makes certain addition or the Assessing Officer disallowance and in making such additions or had dealt with the issue disallowances, he deals with such item or in the assessment and items of income in the body of order of was the subject-matter assessment but he under assessed such sums; of appeal c Assessing Officer makes

VAKSONS METAPLAST PVT LTD,DELHI vs. PCIT(CENTRAL), DELHI

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

Bench: Shris.Rifaur Rahman & Shri Anubhav Sharma

1) (a) where Officer makes certain addition or the Assessing Officer disallowance and in making such additions or had dealt with the issue disallowances, he deals with such item or in the assessment and items of income in the body of order of was the subject-matter assessment but he under assessed such sums; of appeal c Assessing Officer makes

VAKSONS METAPLAST PVT LTD,DELHI vs. PCIT(CENTRAL), DELHI

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

Bench: Shris.Rifaur Rahman & Shri Anubhav Sharma

1) (a) where Officer makes certain addition or the Assessing Officer disallowance and in making such additions or had dealt with the issue disallowances, he deals with such item or in the assessment and items of income in the body of order of was the subject-matter assessment but he under assessed such sums; of appeal c Assessing Officer makes

THOMSON PRESS (INDIA) LTD vs. COMMISSIONER OF INCOME TAX-II

263(1) of the Act were available only if the order sought to be reviewed was prejudicial to the interests of the revenue and was unsustainable in law. 26. In view of the settled law as indicated above, the issue to be considered is whether the claim of the Assessee for including notional interest as profit and gains derived from

THOMSON PRESS (INDIA) LTD vs. COMMISSIONER OF INCOME TAX-II

263(1) of the Act were available only if the order sought to be reviewed was prejudicial to the interests of the revenue and was unsustainable in law. 26. In view of the settled law as indicated above, the issue to be considered is whether the claim of the Assessee for including notional interest as profit and gains derived from

THOMSON PRESS (INDIA) LTD. vs. COMMISSIONER OF INCOME TAX-II

263(1) of the Act were available only if the order sought to be reviewed was prejudicial to the interests of the revenue and was unsustainable in law. 26. In view of the settled law as indicated above, the issue to be considered is whether the claim of the Assessee for including notional interest as profit and gains derived from

THOMSON PRESS (INDIA) LTD. vs. COMMISSIONER OF INCOME TAX-II

263(1) of the Act were available only if the order sought to be reviewed was prejudicial to the interests of the revenue and was unsustainable in law. 26. In view of the settled law as indicated above, the issue to be considered is whether the claim of the Assessee for including notional interest as profit and gains derived from

JAGRITI JOB FINDER PRIVATE LIMITED,NEW DELHI vs. PCIT CENTRAL - 1, NEW DELHI

In the result, the appeal of the assessee is allowed

Bench: Ms.Madhumita Roy & Shri Avdhesh Kumar Mishram/S Jagriti Job Finder Vs. Pcit (Central) -1 Private Limited, 222, 2Nd New Delhi-110055 Floor Hemkunt Chamber, 89, Nehru Place, New Delhi – 110019 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aabcj5974E Appellant .. Respondent

disallowed as per under 14A - 1% of the average investment of Rs.1,12,73,766” 5. In that view of the matter the assessee was directed to explain as to why proceeding under Section 263

VENETIAN LDF PROJECTS LLP,GURGAON vs. ACIT CIRCLE-4(1), GURGAON

In the result, grounds raised by the assessee are dismissed

Bench: Shri S. Rifaur Rahman & Shri Vimal Kumar

section 263 of the Act. 45 173 In fact, it is pertinent to note that section 263 nowhere refers to an assessment order passed by the NaFAC under section 144B of the Faceless Assessment Scheme to be subjected to revisionary jurisdiction. It only confers revisionary jurisdiction to revise any order passed by the ‘Assessing Officer’ or the ‘Transfer Pricing Officer

AMAZON SMART COMMERCE SOLUTIONS PRIVATE LIMITED,DELHI vs. PRINCIPAL COMMISSIONER OF INCOME TAX, DELHI-1, DELHI

In the result, grounds raised by the assessee are dismissed

section 263 on the issue of reversal of provision for doubtful advances, is without jurisdiction and bad in law.\n10. 1. Without prejudice, the PCIT erred in issuing vague/open ended directions to the assessing officer to examine the genuineness of the claim without appreciating that the appellant has claimed only reversal of provision for doubtful advances which was suo motu

MICROMAX INFORMATICS LTD,NEW DELHI vs. PCIT, DELHI

In the result, the appeal of the assessee is allowed

Bench: Shri Challa Nagendra Prasad & Shri Avdhesh Kumar Mishra

disallowances of the same under section 14A of the Act. The relevant part of the decision of the Hon’ble Delhi High Court in the case of Clix Finance India Pvt. (supra) reads as under: 19. A bare reading of sub-Section (1) of Section 263

ASSOTECH MOONSHINE URBAN DEVELOPERS P.LTD,NEW DELHI vs. ACIT, CIRCLE-1(1), NEW DELHI

In the result, the appeal of the assessee is allowed

Bench: Shri Challa Nagendra Prasad & Shri Avdhesh Kumar Mishra

disallowances of the same under section 14A of the Act. The relevant part of the decision of the Hon’ble Delhi High Court in the case of Clix Finance India Pvt. (supra) reads as under: 19. A bare reading of sub-Section (1) of Section 263

ANKUR GOYAL,GHAZIABAD vs. ITO, WARD 1(1), GHAZIABAD

In the result, the appeal of the assessee is allowed

Bench: Shri Challa Nagendra Prasad & Shri Avdhesh Kumar Mishra

disallowances of the same under section 14A of the Act. The relevant part of the decision of the Hon’ble Delhi High Court in the case of Clix Finance India Pvt. (supra) reads as under: 19. A bare reading of sub-Section (1) of Section 263

JINDAL POLYBUTTONS PVT LTD,DELHI vs. PR CIT, ROHTAK

In the result, both the assessee's appeals stand allowed

Bench: Shri Shamim Yahya & Shri Sudhir Pareek

1. That the Ld. PCIT has erred on facts and in law in passing the order under Section 263 holding that the assessment made by the AO under Section 147 read with Section 143(3) of the Act, is erroneous as well as prejudicial to the interest of the revenue. 2. That on the facts and circumstances of the case

JINDAL POLYBUTTONS PVT LTD,DELHI vs. PCIT, ROHTAK

In the result, both the assessee's appeals stand allowed

Bench: Shri Shamim Yahya & Shri Sudhir Pareek

1. That the Ld. PCIT has erred on facts and in law in passing the order under Section 263 holding that the assessment made by the AO under Section 147 read with Section 143(3) of the Act, is erroneous as well as prejudicial to the interest of the revenue. 2. That on the facts and circumstances of the case

MUKUL ROHATGI,NEW DELHI vs. ACIT CIRCLE 61(1), NEW DELHI

In the result, the appeal of the assessee is allowed

Bench: Shri Mahavir Singh & Shri Manish Agarwal

disallowed a sum of ₹40,10,848/- under Section 14A read with Rule 8D of the Income-tax Rules, 1962 (hereinafter ‘the rules'). The PCIT called and examined the records and accordingly, notice under Section 263 of the Act dated 11th March, 2025 was issued, giving show cause notice with intent to revise the assessment under Section 263

KAUR KOOKIES (P) LTD.,NEW DELHI vs. PR,CIT, DELHI-4, NEW DELHI

Appeal are allowed

Bench: Shri Kul Bharat & Shri Pradip Kumar Kediaassessment Year: 2017-18

263 of the Act. 2 Issue No. 1 2.1 It is submitted that learned Pr. Commissioner of Income Tax in revision order has held that sum of Rs. 3,48,324/- has not been considered for disallowance in return of income by relying upon tax audit report (hereinafter referred to as “TAR”) furnished by learned Auditor (para 9.1 - 9.2, page