https://www.taxtmi.com/caselaws?id=445609 ITAT Ahmedabad quashed PCIT's revision order under section 263 regarding denial of bank guarantee commission expenditure claim under section 37. The assessee had provided detailed bank guarantee information including BG numbers, commission details, and related expenses in response to AO's section 142(1) notice during assessment proceedings. ITAT held that PCIT failed to consider the complete assessment record and the assessee's reply, making the revision order legally impermissible. The order was not erroneous or prejudicial to revenue interest as required under section 263, following Supreme Court precedent in Malabar Industrial Co. Ltd. case. en-us Wed, 08 Nov 2023 00:00:00 +0530 Fri, 10 Nov 2023 14:35:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=445609 ITAT Ahmedabad quashed PCIT's revision order under section 263 regarding denial of bank guarantee commission expenditure claim under section 37. The assessee had provided detailed bank guarantee information including BG numbers, commission details, and related expenses in response to AO's section 142(1) notice during assessment proceedings. ITAT held that PCIT failed to consider the complete assessment record and the assessee's reply, making the revision order legally impermissible. The order was not erroneous or prejudicial to revenue interest as required under section 263, following Supreme Court precedent in Malabar Industrial Co. Ltd. case. Case-Laws Income Tax Wed, 08 Nov 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=445609