https://www.taxtmi.com/caselaws?id=457070 The ITAT Jaipur allowed the assessee's appeal against revision u/s 263. The PCIT had directed disallowance u/s 14A regarding interest paid on partners' capital accounts. The tribunal held that when PCIT takes a conscious view on a debatable legal issue, it cannot constitute a mistake apparent on record under s 263. The tribunal noted that interest on partners' capital accounts represents profit allocation, not business expenditure, and multiple precedents support non-applicability of s 14A disallowance to such payments. The PCIT's reliance on Munjal Sales Corporation was deemed inapplicable as it predated s 14A's introduction in 2001. en-us Wed, 30 Aug 2023 00:00:00 +0530 Wed, 04 Sep 2024 20:04:25 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=457070 The ITAT Jaipur allowed the assessee's appeal against revision u/s 263. The PCIT had directed disallowance u/s 14A regarding interest paid on partners' capital accounts. The tribunal held that when PCIT takes a conscious view on a debatable legal issue, it cannot constitute a mistake apparent on record under s 263. The tribunal noted that interest on partners' capital accounts represents profit allocation, not business expenditure, and multiple precedents support non-applicability of s 14A disallowance to such payments. The PCIT's reliance on Munjal Sales Corporation was deemed inapplicable as it predated s 14A's introduction in 2001. Case-Laws Income Tax Wed, 30 Aug 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=457070