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RU
ITAT Mumbai: Section 263 Revision Quashed as AO Examined Section 57(iii) Interest Claim
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According to the PCIT, the Assessing Officer had allowed the interest deduction without making the inquiry and verification that should have been undertaken.
Before the Tribunal, the assessee’s counsel submitted that the Assessing Officer had, in fact, conducted a detailed inquiry into the Section 57(iii) claim.
It noted that the PCIT’s principal basis for exercising Section 263 jurisdiction was the alleged absence of inquiry by the Assessing Officer.
The Assessing Officer was satisfied that the interest expenditure had been incurred wholly and exclusively for earning the interest income offered under the head “Income from Other Sources”.
It set aside the impugned revisionary order passed by the PCIT under Section 263 and restored the assessment order dated 08.09.2022.