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ITAT partially allowed the appellant's appeal against revision proceedings under section 263. Regarding excess deduction under section 35CCC, the Tribunal upheld the revision but modified the disallowance amount to INR 8,03,76,735 instead of INR 10,68,11,066 as directed by PCIT. On the section 14A disallowance issue, ITAT found that the AO had properly examined the matter during assessment proceedings, making revision unwarranted. The Tribunal noted that CBDT Circular No. 5 of 2014 was inapplicable as the appellant had actually earned exempt dividend income. Similarly, regarding depreciation on land value, ITAT held that the AO had made proper inquiry after considering the appellant's submissions and litigation history.
ITAT partially allowed the appellant's appeal against revision proceedings under section 263. Regarding excess deduction under section 35CCC, the Tribunal upheld the revision but modified the disallowance amount to INR 8,03,76,735 instead of INR 10,68,11,066 as directed by PCIT. On the section 14A disallowance issue, ITAT found that the AO had properly examined the matter during assessment proceedings, making revision unwarranted. The Tribunal noted that CBDT Circular No. 5 of 2014 was inapplicable as the appellant had actually earned exempt dividend income. Similarly, regarding depreciation on land value, ITAT held that the AO had made proper inquiry after considering the appellant's submissions and litigation history.
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