https://www.taxtmi.com/caselaws?id=775423 The ITAT Ahmedabad held that the PCIT's revision under section 263 was unsustainable. The PCIT failed to conclusively establish that the additional depreciation claims on the camera, air conditioner, and factory building were wrongly allowed. The PCIT improperly usurped the AO's power under section 14A by directing disallowance of expenses without the AO recording dissatisfaction with the assessee's explanation, contrary to Supreme Court precedent. The PCIT's interpretation requiring reduction of written down value by brought-forward additional depreciation was rejected as contrary to statutory language and settled principles of statutory interpretation. The revisionary power under section 263 was found to be misused over a trivial claim that would be allowable in subsequent years. The appeal was allowed, and the PCIT's directions to disallow depreciation and expenses were set aside. en-us Mon, 21 Jul 2025 00:00:00 +0530 Fri, 25 Jul 2025 08:28:06 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=775423 The ITAT Ahmedabad held that the PCIT's revision under section 263 was unsustainable. The PCIT failed to conclusively establish that the additional depreciation claims on the camera, air conditioner, and factory building were wrongly allowed. The PCIT improperly usurped the AO's power under section 14A by directing disallowance of expenses without the AO recording dissatisfaction with the assessee's explanation, contrary to Supreme Court precedent. The PCIT's interpretation requiring reduction of written down value by brought-forward additional depreciation was rejected as contrary to statutory language and settled principles of statutory interpretation. The revisionary power under section 263 was found to be misused over a trivial claim that would be allowable in subsequent years. The appeal was allowed, and the PCIT's directions to disallow depreciation and expenses were set aside. Case-Laws Income Tax Mon, 21 Jul 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=775423