https://www.taxtmi.com/caselaws?id=759425 ITAT Ahmedabad allowed the assessee's appeal against PCIT's revision order u/s 263. The assessee borrowed loans at 12.75% interest and lent at 12%, restricting interest expense claims to 12% under section 57. PCIT alleged inadequate inquiry regarding nexus between borrowings and advances, and unexplained cash credits. ITAT held that PCIT failed to demonstrate the assessment order was erroneous and prejudicial to revenue, citing Malabar Industrial Co. Ltd. precedent that section 263 cannot correct every error but only those rendering assessment erroneous. AO had conducted necessary inquiries and applied proper judgment. The revision order was unsustainable in law. en-us Mon, 23 Sep 2024 00:00:00 +0530 Mon, 30 Sep 2024 12:25:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=759425 ITAT Ahmedabad allowed the assessee's appeal against PCIT's revision order u/s 263. The assessee borrowed loans at 12.75% interest and lent at 12%, restricting interest expense claims to 12% under section 57. PCIT alleged inadequate inquiry regarding nexus between borrowings and advances, and unexplained cash credits. ITAT held that PCIT failed to demonstrate the assessment order was erroneous and prejudicial to revenue, citing Malabar Industrial Co. Ltd. precedent that section 263 cannot correct every error but only those rendering assessment erroneous. AO had conducted necessary inquiries and applied proper judgment. The revision order was unsustainable in law. Case-Laws Income Tax Mon, 23 Sep 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=759425