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    <title>2024 (11) TMI 860 - ITAT AMRITSAR</title>
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    <description>The ITAT Amritsar allowed the assessee&#039;s appeal against revision u/s 263 by PCIT. The tribunal held that the assessee maintained separate books of accounts for eligible and non-eligible units using SAP software, with proper records submitted to AO and TPO. The AO had conducted detailed enquiry and examination during assessment u/s 143(3). The PCIT&#039;s invocation of section 263 was based solely on audit objections without independent application of mind, which was held to be bad in law. Revenue failed to demonstrate how the AO&#039;s order was erroneous or prejudicial to revenue interests, as all requisite documents were properly verified by authorities.</description>
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    <pubDate>Wed, 09 Oct 2024 00:00:00 +0530</pubDate>
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      <title>2024 (11) TMI 860 - ITAT AMRITSAR</title>
      <link>https://www.taxtmi.com/caselaws?id=761874</link>
      <description>The ITAT Amritsar allowed the assessee&#039;s appeal against revision u/s 263 by PCIT. The tribunal held that the assessee maintained separate books of accounts for eligible and non-eligible units using SAP software, with proper records submitted to AO and TPO. The AO had conducted detailed enquiry and examination during assessment u/s 143(3). The PCIT&#039;s invocation of section 263 was based solely on audit objections without independent application of mind, which was held to be bad in law. Revenue failed to demonstrate how the AO&#039;s order was erroneous or prejudicial to revenue interests, as all requisite documents were properly verified by authorities.</description>
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      <pubDate>Wed, 09 Oct 2024 00:00:00 +0530</pubDate>
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