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The ITAT upheld the PCIT's exercise of revisionary jurisdiction under s.263, holding that s.263 is available to correct an order erroneous and prejudicial to the revenue even where the error is apparent from the record and potentially rectifiable under s.154 or s.147. The AO's order was found erroneous and prejudicial for disallowing depreciation on goodwill to the extent of Rs.10,89,82,058 as against the claim of Rs.27,63,20,888, and the PCIT's directions under s.263 were sustained. Merits of the depreciation claim (including reliance on judicial precedents) were left to the pending appeal against quantum before the ld. CIT(A). The assessee's appeal is dismissed.
The ITAT upheld the PCIT's exercise of revisionary jurisdiction under s.263, holding that s.263 is available to correct an order erroneous and prejudicial to the revenue even where the error is apparent from the record and potentially rectifiable under s.154 or s.147. The AO's order was found erroneous and prejudicial for disallowing depreciation on goodwill to the extent of Rs.10,89,82,058 as against the claim of Rs.27,63,20,888, and the PCIT's directions under s.263 were sustained. Merits of the depreciation claim (including reliance on judicial precedents) were left to the pending appeal against quantum before the ld. CIT(A). The assessee's appeal is dismissed.
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