https://www.taxtmi.com/caselaws?id=761289 ITAT Ahmedabad allowed the assessee's appeal against CIT's revision u/s 263. CIT had deemed the assessment order erroneous for not disallowing interest paid under sections 201(1A) and 206C(7) for late TDS payment, which auditors categorized as penalties. ITAT held that following judicial precedents including Resolve Salvage Fire India (P.) Ltd, such interest is compensatory in nature and allowable as deduction. Citing CIT vs. Sunbeam Auto, ITAT ruled that when AO takes a legally plausible view supported by precedents, CIT cannot substitute another view through section 263 proceedings unless the AO's view is wholly unsustainable. en-us Wed, 23 Oct 2024 00:00:00 +0530 Thu, 07 Nov 2024 08:52:11 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=761289 ITAT Ahmedabad allowed the assessee's appeal against CIT's revision u/s 263. CIT had deemed the assessment order erroneous for not disallowing interest paid under sections 201(1A) and 206C(7) for late TDS payment, which auditors categorized as penalties. ITAT held that following judicial precedents including Resolve Salvage Fire India (P.) Ltd, such interest is compensatory in nature and allowable as deduction. Citing CIT vs. Sunbeam Auto, ITAT ruled that when AO takes a legally plausible view supported by precedents, CIT cannot substitute another view through section 263 proceedings unless the AO's view is wholly unsustainable. Case-Laws Income Tax Wed, 23 Oct 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=761289