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    <title>2025 (12) TMI 738 - ITAT AHMEDABAD</title>
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    <description>ITAT Ahmedabad set aside the revision order u/s 263 passed by PCIT and restored the original assessment. The Tribunal held that the assessment order was neither erroneous nor prejudicial to the interests of the Revenue. The assessee had substantiated that TDS was duly deducted on commission, brokerage and professional/technical fees, including on advances, and that expenditure was claimed in appropriate years. The assessee also demonstrated that loans were taken through banking channels and the contrary remark in the audit report was a clerical error already examined by the AO. ITAT held that PCIT acted mechanically without proper application of mind, rendering the s.263 revision unsustainable.</description>
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    <pubDate>Tue, 09 Dec 2025 00:00:00 +0530</pubDate>
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      <title>2025 (12) TMI 738 - ITAT AHMEDABAD</title>
      <link>https://www.taxtmi.com/caselaws?id=783198</link>
      <description>ITAT Ahmedabad set aside the revision order u/s 263 passed by PCIT and restored the original assessment. The Tribunal held that the assessment order was neither erroneous nor prejudicial to the interests of the Revenue. The assessee had substantiated that TDS was duly deducted on commission, brokerage and professional/technical fees, including on advances, and that expenditure was claimed in appropriate years. The assessee also demonstrated that loans were taken through banking channels and the contrary remark in the audit report was a clerical error already examined by the AO. ITAT held that PCIT acted mechanically without proper application of mind, rendering the s.263 revision unsustainable.</description>
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      <pubDate>Tue, 09 Dec 2025 00:00:00 +0530</pubDate>
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