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    <title>2025 (11) TMI 1763 - ITAT AHMEDABAD</title>
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    <description>ITAT Ahmedabad upheld the PCIT&#039;s revision u/s 263 in part. It held that the AO had not examined the assessee&#039;s excess claim of deduction u/s 32AC on new plant and machinery, nor the accounting treatment of a remaining government grant of Rs. 49 lakhs, rendering the assessment order erroneous and prejudicial to Revenue. The assessee failed to substantiate eligibility for the additional 32AC deduction or provide specific details on the grant&#039;s treatment. Accordingly, PCIT&#039;s directions on these two issues were sustained. However, the finding that the assessment was erroneous for non-examination of transactions with M/s Ravi Trading Co. was set aside for breach of natural justice, as this ground had not been properly confronted to the assessee.</description>
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    <pubDate>Fri, 26 Sep 2025 00:00:00 +0530</pubDate>
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      <title>2025 (11) TMI 1763 - ITAT AHMEDABAD</title>
      <link>https://www.taxtmi.com/caselaws?id=782295</link>
      <description>ITAT Ahmedabad upheld the PCIT&#039;s revision u/s 263 in part. It held that the AO had not examined the assessee&#039;s excess claim of deduction u/s 32AC on new plant and machinery, nor the accounting treatment of a remaining government grant of Rs. 49 lakhs, rendering the assessment order erroneous and prejudicial to Revenue. The assessee failed to substantiate eligibility for the additional 32AC deduction or provide specific details on the grant&#039;s treatment. Accordingly, PCIT&#039;s directions on these two issues were sustained. However, the finding that the assessment was erroneous for non-examination of transactions with M/s Ravi Trading Co. was set aside for breach of natural justice, as this ground had not been properly confronted to the assessee.</description>
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      <pubDate>Fri, 26 Sep 2025 00:00:00 +0530</pubDate>
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