https://www.taxtmi.com/caselaws?id=773873 The ITAT upheld the PCIT's revision order under section 263, finding the original assessment order erroneous and prejudicial to revenue interests. The AO failed to examine the applicability of section 40(a)(iib) regarding guarantee commission fees paid to Kerala State Government, mechanically accepting the assessee's claim without proper scrutiny. The tribunal ruled that non-examination of material issues constitutes a palpable error warranting revision, as the AO showed no application of mind in allowing the deduction. The appeal was decided against the assessee. en-us Wed, 14 May 2025 00:00:00 +0530 Mon, 30 Jun 2025 08:43:50 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=773873 The ITAT upheld the PCIT's revision order under section 263, finding the original assessment order erroneous and prejudicial to revenue interests. The AO failed to examine the applicability of section 40(a)(iib) regarding guarantee commission fees paid to Kerala State Government, mechanically accepting the assessee's claim without proper scrutiny. The tribunal ruled that non-examination of material issues constitutes a palpable error warranting revision, as the AO showed no application of mind in allowing the deduction. The appeal was decided against the assessee. Case-Laws Income Tax Wed, 14 May 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=773873