https://www.taxtmi.com/caselaws?id=449004 The ITAT Mumbai upheld the CIT's revision order under section 263, rejecting the assessee's challenge. The CIT properly exercised revisional jurisdiction after independently examining records, despite the AO's initial proposal. The AO failed to make timely reference to the TPO - although approval was received on 09/03/2021, the AO delayed until 20/09/2021, well past the 31/07/2021 deadline. This time-barred reference was invalid, making the assessment erroneous and prejudicial to revenue interests. The tribunal rejected the assessee's argument regarding ITBA portal dates, emphasizing that statutory limitations under the Act govern proceedings, not portal entries. en-us Wed, 31 Jan 2024 00:00:00 +0530 Sat, 03 Feb 2024 08:25:49 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=449004 The ITAT Mumbai upheld the CIT's revision order under section 263, rejecting the assessee's challenge. The CIT properly exercised revisional jurisdiction after independently examining records, despite the AO's initial proposal. The AO failed to make timely reference to the TPO - although approval was received on 09/03/2021, the AO delayed until 20/09/2021, well past the 31/07/2021 deadline. This time-barred reference was invalid, making the assessment erroneous and prejudicial to revenue interests. The tribunal rejected the assessee's argument regarding ITBA portal dates, emphasizing that statutory limitations under the Act govern proceedings, not portal entries. Case-Laws Income Tax Wed, 31 Jan 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=449004