https://www.taxtmi.com/caselaws?id=755734 The ITAT Ahmedabad allowed the assessee's appeal against a revision order u/s 263 regarding business promotion expenses claimed u/s 37. The PCIT had revised the assessment order, arguing that business promotion expenses were freebies/monetary grants requiring disallowance and that the AO failed to conduct proper enquiry. The ITAT held that the AO had adequately enquired and applied his mind before allowing the claim. The PCIT failed to substantiate allegations or prove inadequacy in the AO's enquiry, basing the revision merely on a different opinion. Since powers u/s 263 cannot be exercised solely on change of opinion without establishing the order was erroneous and prejudicial to revenue, the revision was set aside. en-us Fri, 05 Jul 2024 00:00:00 +0530 Thu, 18 Jul 2024 06:53:49 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=755734 The ITAT Ahmedabad allowed the assessee's appeal against a revision order u/s 263 regarding business promotion expenses claimed u/s 37. The PCIT had revised the assessment order, arguing that business promotion expenses were freebies/monetary grants requiring disallowance and that the AO failed to conduct proper enquiry. The ITAT held that the AO had adequately enquired and applied his mind before allowing the claim. The PCIT failed to substantiate allegations or prove inadequacy in the AO's enquiry, basing the revision merely on a different opinion. Since powers u/s 263 cannot be exercised solely on change of opinion without establishing the order was erroneous and prejudicial to revenue, the revision was set aside. Case-Laws Income Tax Fri, 05 Jul 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=755734