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The HC upheld ITAT's decision dismissing the CIT's revision petition under Section 263 of the IT Act. The assessee claimed deductions under Sections 80IA(4), 80G, and 37(1) including freight charges and donations to Prime Minister's National Relief Fund. The ITAT found that PCIT failed to conduct independent enquiry or identify specific errors in the assessment order. The AO had exercised due diligence and applied judicial mind before passing the assessment order. Both twin conditions under Section 263 - that the order must be erroneous and prejudicial to revenue interests - were not satisfied. The HC concluded that ITAT's factual findings were neither perverse nor contrary to record, warranting no interference. The revision petition was dismissed in favor of the assessee.
The HC upheld ITAT's decision dismissing the CIT's revision petition under Section 263 of the IT Act. The assessee claimed deductions under Sections 80IA(4), 80G, and 37(1) including freight charges and donations to Prime Minister's National Relief Fund. The ITAT found that PCIT failed to conduct independent enquiry or identify specific errors in the assessment order. The AO had exercised due diligence and applied judicial mind before passing the assessment order. Both twin conditions under Section 263 - that the order must be erroneous and prejudicial to revenue interests - were not satisfied. The HC concluded that ITAT's factual findings were neither perverse nor contrary to record, warranting no interference. The revision petition was dismissed in favor of the assessee.
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