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The ITAT upheld the PCIT's revision under s.263, finding the AO's assessment order erroneous and prejudicial to revenue interests. The Tribunal confirmed the AO failed to conduct proper inquiry regarding TDS compliance on expenses exceeding Rs.31 crore potentially covered under ss.194C, 194J, and 192, and did not examine s.40(a)(ia) implications. However, the ITAT modified the PCIT's direction for blanket 30% disallowance of expenses, instructing the AO to verify whether TDS was required on daily wages and labor charges, allowing expenses below threshold limits. The Tribunal also confirmed the addition under s.50C as the difference between stamp duty value and sale consideration was 9.02%, exceeding the then-applicable tolerance limit of 5%. The assessee's appeal was partly allowed.
The ITAT upheld the PCIT's revision under s.263, finding the AO's assessment order erroneous and prejudicial to revenue interests. The Tribunal confirmed the AO failed to conduct proper inquiry regarding TDS compliance on expenses exceeding Rs.31 crore potentially covered under ss.194C, 194J, and 192, and did not examine s.40(a)(ia) implications. However, the ITAT modified the PCIT's direction for blanket 30% disallowance of expenses, instructing the AO to verify whether TDS was required on daily wages and labor charges, allowing expenses below threshold limits. The Tribunal also confirmed the addition under s.50C as the difference between stamp duty value and sale consideration was 9.02%, exceeding the then-applicable tolerance limit of 5%. The assessee's appeal was partly allowed.
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