ITAT dismissed the assessee's appeal and upheld the PCIT's...

ITAT dismissed the assessee's appeal and upheld the PCIT's revisional order u/s 263. It held that the reassessment order dated 30.03.2023 was an "order" independent of the original assessment and was within the limitation period prescribed in s.263(2), hence not barred by limitation. Adequate opportunity of hearing was found to have been afforded through multiple notices and written submissions, satisfying the requirement of s.263, including by electronic mode as per s.2(23C). The AO's failure to disallow delayed employees' PF/ESI contributions, contrary to s.36(1)(va) and binding precedent, rendered the reassessment order both erroneous and prejudicial to the revenue. The ground on customs duty fine/penalty was not pressed and stood rejected.

---