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INCOME TAX APPELLATE TRIBUNAL (DELHI BENCH)
M. Balaganesh, A.M., Yogesh Kumar U.S., J.
M/s. Corporate International Financial Services Ltd – Appellant
Versus
PCIT (central), Delhi-1 – Respondent
| Table of Content |
|---|
| 1. justification of invoking revision jurisdiction under section 263. (Para 3) |
| 2. assessment completion details relating to unsecured loans. (Para 4) |
| 3. contentions by the ar and dr regarding the legitimacy of revision. (Para 5 , 6) |
| 4. court's findings against the invocation of revision jurisdiction. (Para 7) |
| 5. conclusion allowing the appeals. (Para 8 , 10 , 12) |
| 6. additional violation of natural justice regarding chargeability of interest. (Para 9) |
PER M. BALAGANESH, A. M.:
1. The appeals in ITA Nos. 218, 220, 221, 223, 240, 349 & 243/Del/2021 for AYs 2013-14 to 2019-20, arise out of the order of the Pr. Commissioner of Income Tax-1, New Delhi [hereinafter referred to as „ld. PCIT‟, in short] in Proceedings No. TBA/REV/F/REV5/2023- 24/1058852277(1) under section 263 of the Income Tax Act, 1961 (hereinafter referred to as the Act) dated 18.12.2023 against the order of assessment passed u/s 143(3) of the Act dated 21.04.2021 by the ACIT, Circle-4, New Delhi (hereinafter referred to as „ld. AO‟).
2. All the appeals are having identical issues and hence they are taken up together and disposed of by this common order for the sake of convenience. With the consent of both th
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