https://www.taxtmi.com/caselaws?id=462806 The ITAT Delhi allowed the assessee's appeal against CIT's revision order u/s 263. The CIT had set aside AO's assessment orders u/s 153A, directing fresh orders on disallowance u/s 14A r/w Rule 8D, claiming the original orders were erroneous and prejudicial to Revenue's interest. The Tribunal held that since the assessee earned no exempt income in the relevant assessment year, no disallowance u/s 14A could be made, citing PCIT vs. IL & FS Energy Development Company Ltd. precedent. The Tribunal concluded that AO's assessment orders were not erroneous and prejudicial to Revenue's interest, as twin conditions for invoking section 263 were not satisfied, thereby allowing the assessee's appeal. en-us Tue, 31 Dec 2024 00:00:00 +0530 Wed, 16 Jul 2025 23:42:42 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=462806 The ITAT Delhi allowed the assessee's appeal against CIT's revision order u/s 263. The CIT had set aside AO's assessment orders u/s 153A, directing fresh orders on disallowance u/s 14A r/w Rule 8D, claiming the original orders were erroneous and prejudicial to Revenue's interest. The Tribunal held that since the assessee earned no exempt income in the relevant assessment year, no disallowance u/s 14A could be made, citing PCIT vs. IL & FS Energy Development Company Ltd. precedent. The Tribunal concluded that AO's assessment orders were not erroneous and prejudicial to Revenue's interest, as twin conditions for invoking section 263 were not satisfied, thereby allowing the assessee's appeal. Case-Laws Income Tax Tue, 31 Dec 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=462806