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    <title>2025 (2) TMI 1811 - ITAT KOLKATA</title>
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    <description>An assessment order was held erroneous and prejudicial to the interests of the Revenue where interest on delayed TDS payment was treated as an inadmissible business expenditure, justifying revision under section 263 of the Income-tax Act, 1961. The objection that prior approval under section 153D barred revision was rejected because such approval had been granted by the Joint Commissioner, while revisional power under section 263 vests in the Principal Commissioner or a higher authority. The cited precedent was found inapplicable on the facts, and no further deep enquiry was required for invoking revision. The revisional order was sustained and the assessee&#039;s challenge failed.</description>
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      <link>https://www.taxtmi.com/caselaws?id=468580</link>
      <description>An assessment order was held erroneous and prejudicial to the interests of the Revenue where interest on delayed TDS payment was treated as an inadmissible business expenditure, justifying revision under section 263 of the Income-tax Act, 1961. The objection that prior approval under section 153D barred revision was rejected because such approval had been granted by the Joint Commissioner, while revisional power under section 263 vests in the Principal Commissioner or a higher authority. The cited precedent was found inapplicable on the facts, and no further deep enquiry was required for invoking revision. The revisional order was sustained and the assessee&#039;s challenge failed.</description>
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