https://www.taxtmi.com/caselaws?id=450597 ITAT Kolkata held that PCIT's revision u/s 263 was unsustainable on two grounds. First, section 56(2)(x) provisions do not apply to acquisition of leasehold rights in land and building, making PCIT's direction to examine such transactions legally untenable. Second, regarding reversal of provisions created in earlier years, the assessee properly demonstrated that deductions were not claimed as expenses when provisions were created, being disallowed under section 43B. PCIT failed to provide objective findings despite detailed reconciliation provided by assessee. The revisionary jurisdiction was invalid as PCIT did not establish how the assessment was erroneous. Appeal allowed. en-us Wed, 06 Mar 2024 00:00:00 +0530 Thu, 07 Mar 2024 11:51:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=450597 ITAT Kolkata held that PCIT's revision u/s 263 was unsustainable on two grounds. First, section 56(2)(x) provisions do not apply to acquisition of leasehold rights in land and building, making PCIT's direction to examine such transactions legally untenable. Second, regarding reversal of provisions created in earlier years, the assessee properly demonstrated that deductions were not claimed as expenses when provisions were created, being disallowed under section 43B. PCIT failed to provide objective findings despite detailed reconciliation provided by assessee. The revisionary jurisdiction was invalid as PCIT did not establish how the assessment was erroneous. Appeal allowed. Case-Laws Income Tax Wed, 06 Mar 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=450597