https://www.taxtmi.com/caselaws?id=353338 The Tribunal upheld the Pr. CIT's jurisdiction under section 263, finding the AO's failure to investigate the applicability of section 194A on factoring charges as erroneous. However, the Tribunal left open the question of whether factoring charges constitute interest under section 2(28A) and disregarded the Pr. CIT's views on the retrospective application of the second proviso to section 40(a)(ia). The Tribunal partially allowed the appeal, instructing the AO to re-evaluate the factoring charges independently of the Pr. CIT's opinions on their nature and the retrospective proviso application. en-us Wed, 25 Oct 2017 00:00:00 +0530 Tue, 02 Jan 2018 08:59:52 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=353338 The Tribunal upheld the Pr. CIT's jurisdiction under section 263, finding the AO's failure to investigate the applicability of section 194A on factoring charges as erroneous. However, the Tribunal left open the question of whether factoring charges constitute interest under section 2(28A) and disregarded the Pr. CIT's views on the retrospective application of the second proviso to section 40(a)(ia). The Tribunal partially allowed the appeal, instructing the AO to re-evaluate the factoring charges independently of the Pr. CIT's opinions on their nature and the retrospective proviso application. Case-Laws Income Tax Wed, 25 Oct 2017 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=353338