https://www.taxtmi.com/caselaws?id=780862 ITAT MUMBAI - AT held that the revision under s.263 disallowing marketing research, recruitment and retainership fees and directing amortisation under s.35D was unsustainable. The Tribunal found s.35D inapplicable as the expenses were neither pre-commencement nor incurred on expansion/new unit, and the AO reasonably allowed the s.37(1) deductions after enquiry and examination of evidence. The PCIT's mere disagreement with the AO's view did not render the assessment order erroneous or prejudicial; therefore the s.263 revision lacked jurisdiction and the appeal was allowed in favour of the assessee. en-us Tue, 14 Oct 2025 00:00:00 +0530 Fri, 07 Nov 2025 08:37:27 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=780862 ITAT MUMBAI - AT held that the revision under s.263 disallowing marketing research, recruitment and retainership fees and directing amortisation under s.35D was unsustainable. The Tribunal found s.35D inapplicable as the expenses were neither pre-commencement nor incurred on expansion/new unit, and the AO reasonably allowed the s.37(1) deductions after enquiry and examination of evidence. The PCIT's mere disagreement with the AO's view did not render the assessment order erroneous or prejudicial; therefore the s.263 revision lacked jurisdiction and the appeal was allowed in favour of the assessee. Case-Laws Income Tax Tue, 14 Oct 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=780862