https://www.taxtmi.com/caselaws?id=355086 Section 263 revision was upheld because the assessment order showed no real examination of the allowability of transfers to general reserve, education reserve and gratuity provision. Mere reproduction of accounting entries was treated as insufficient to show application of mind, so the order was considered erroneous and prejudicial to the Revenue. The objection that the Principal Commissioner relied only on audit material was rejected because the record was independently examined. The plea of change of opinion and past allowance in earlier years was also rejected, and the deductibility issue was remitted for fresh consideration by the Assessing Officer in accordance with law. en-us Mon, 05 Feb 2018 00:00:00 +0530 Sat, 02 Jun 2018 15:27:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=355086 Section 263 revision was upheld because the assessment order showed no real examination of the allowability of transfers to general reserve, education reserve and gratuity provision. Mere reproduction of accounting entries was treated as insufficient to show application of mind, so the order was considered erroneous and prejudicial to the Revenue. The objection that the Principal Commissioner relied only on audit material was rejected because the record was independently examined. The plea of change of opinion and past allowance in earlier years was also rejected, and the deductibility issue was remitted for fresh consideration by the Assessing Officer in accordance with law. Case-Laws Income Tax Mon, 05 Feb 2018 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=355086