https://www.taxtmi.com/caselaws?id=769643 The ITAT Delhi quashed the PCIT's revision order u/s 263, holding that revision jurisdiction was invalidly assumed. The tribunal found that the AO had conducted adequate enquiries during assessment proceedings despite not recording all enquiries in the assessment order. For legal and professional expenses, loan origination costs, and DSA costs, the AO had made sufficient enquiries and the assessee provided complete details with consistent treatment. Regarding other expenses including year-end provisions, the assessee had suo moto disallowed Rs. 6.77 crores and properly explained the remaining provisions. The PCIT incorrectly treated cost allocation charges as expenditure when they represented income. Finance costs were properly allowable as raw material for the finance company's business. The depreciation claim was correctly made following Supreme Court precedent. Employee benefit expenditure was properly handled with suo moto disallowances under Section 43B. The PCIT's directions amounted to impermissible fishing enquiries without establishing any error in the assessment order. en-us Tue, 15 Apr 2025 00:00:00 +0530 Tue, 29 Apr 2025 08:33:05 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=769643 The ITAT Delhi quashed the PCIT's revision order u/s 263, holding that revision jurisdiction was invalidly assumed. The tribunal found that the AO had conducted adequate enquiries during assessment proceedings despite not recording all enquiries in the assessment order. For legal and professional expenses, loan origination costs, and DSA costs, the AO had made sufficient enquiries and the assessee provided complete details with consistent treatment. Regarding other expenses including year-end provisions, the assessee had suo moto disallowed Rs. 6.77 crores and properly explained the remaining provisions. The PCIT incorrectly treated cost allocation charges as expenditure when they represented income. Finance costs were properly allowable as raw material for the finance company's business. The depreciation claim was correctly made following Supreme Court precedent. Employee benefit expenditure was properly handled with suo moto disallowances under Section 43B. The PCIT's directions amounted to impermissible fishing enquiries without establishing any error in the assessment order. Case-Laws Income Tax Tue, 15 Apr 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=769643