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INCOME TAX APPELLATE TRIBUNAL (BANGALORE BENCH)
George George K, VP, Chandra Poojari, AM
Assessee – Appellant
Versus
PCIT – Respondent
| Table of Content |
|---|
| 1. classification of interest income from statutory deposits as operational income. (Para 1 , 3 , 5 , 10 , 19) |
| 2. arguments against pcit's assessments and revisions. (Para 2 , 4 , 6 , 12 , 14) |
| 3. the court's findings and conclusions on statutory obligations. (Para 8 , 9 , 15 , 18 , 20) |
ORDER
Per George George K, Vice President:
This appeal at the instance of the assessee is directed against PCIT’s order dated 03.11.2023, passed under section 263 of the Income Tax Act, 1961 (hereinafter called ‘the Act’). The relevant Assessment Year is 2018-19.
2. The grounds raised read as follows:
1. The order of the learned P.C.I.T passed u/s. 263 of the Act in so far as it is against the appellant is opposed to law, equity, weight of evidence, probabilities, facts and circumstances of the case.
2. The learned P.C.I.T failed to appreciate that there was no error much less an error prejudicial to the interest of the revenue in the order passed by the learned Assessing Officer warranting revision u/s.263 of the Act and consequently, the order passed by the P.C.I.T. requires to be cancelled.
3. The learned P.C.I.T. is not justified in holding that the order of assessment passed u/s. 143[3]
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