SC upholds CIT's revision under Section 263 on expenditure allowability and loss carry forward claims The SC dismissed the Special Leave Petition challenging the CIT's revision order under section 263 regarding the allowability of expenditure and carry ...
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SC upholds CIT's revision under Section 263 on expenditure allowability and loss carry forward claims
The SC dismissed the Special Leave Petition challenging the CIT's revision order under section 263 regarding the allowability of expenditure and carry forward of losses. The Court held that the ITAT erred in quashing the CIT's order, as the conditions for revision under section 263 were satisfied. The CIT had provided the assessee an opportunity to be heard and directed the AO to verify the claims in accordance with law. The SC found no grounds to interfere under Article 136, leaving all other contentions open.
The Supreme Court, through Hon'ble Justices Abhay S. Oka and Ujjal Bhuyan, after hearing counsel for the petitioner, held that the case was "not a fit case to interfere under Article 136 of the Constitution of India." Consequently, the Special Leave Petition was dismissed. The Court explicitly stated that "all contentions are left open," and any pending applications were disposed of.
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