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ITAT ruled that the CIT's revisionary order under section 263 was unsustainable. The tribunal found the CIT incorrectly characterized the assessee's foreign currency derivative transactions (FCDT) as mark-to-market losses, disregarding evidence of settled losses and hedging activities. The CIT's attempts to invoke section 73's explanation were deemed inappropriate and without legal merit. The tribunal concluded that the CIT misappreciated facts, violated natural justice principles, and erroneously held the original assessment order as invalid. Consequently, the ITAT allowed the assessee's appeal, setting aside the CIT's revisionary order.
ITAT ruled that the CIT's revisionary order under section 263 was unsustainable. The tribunal found the CIT incorrectly characterized the assessee's foreign currency derivative transactions (FCDT) as mark-to-market losses, disregarding evidence of settled losses and hedging activities. The CIT's attempts to invoke section 73's explanation were deemed inappropriate and without legal merit. The tribunal concluded that the CIT misappreciated facts, violated natural justice principles, and erroneously held the original assessment order as invalid. Consequently, the ITAT allowed the assessee's appeal, setting aside the CIT's revisionary order.
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