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ITAT ruled in favor of the assessee, setting aside PCIT's revision order under Section 263. The tribunal found that the assessee could not be held responsible for Form 3CL being in the old format or not electronically filed, as the form is issued by the Department of Scientific and Industrial Research. Similarly, Form 3CLA is to be submitted to the department, not the AO. The in-house R&D centre was approved, and the competent authority had issued Form 3CL as required. Consequently, the PCIT's grounds for revision were deemed unsustainable, and the original assessment order was restored.
ITAT ruled in favor of the assessee, setting aside PCIT's revision order under Section 263. The tribunal found that the assessee could not be held responsible for Form 3CL being in the old format or not electronically filed, as the form is issued by the Department of Scientific and Industrial Research. Similarly, Form 3CLA is to be submitted to the department, not the AO. The in-house R&D centre was approved, and the competent authority had issued Form 3CL as required. Consequently, the PCIT's grounds for revision were deemed unsustainable, and the original assessment order was restored.
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