TaxTMI 
TaxTMI 
2017 (11) TMI 794
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....me Tax Act, 1961 (in short "the Act") dated 20.05.2014 for the Assessment Year 2010-11. 2. The only issue to be decided in this appeal is as to whether the Ld CIT was justified in invoking revisionary jurisdiction in the facts and circumstances of the case. 3. The brief facts off this issue is that the assessee is in the business of providing , inter alia, management consultancy services and also accounting and business advisory services. The company's operations are aggregared into different line of services like advisory and taxation services. The assessee filed its return of income electronically for the Asst Year 2010-11 on 30.3.2012 declaring taxable income of Rs. 33,70,69,038/- . The assessee filed its audited accounts, tax audit re....
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....s applicable on owned premises and not otherwise. Further, it was submitted that the expenditure incurred on account of renovation, interior decoration, etc ought to be considered as an allowable revenue expenditure as such expenses were required to keep the office building and premises not only operational but also in presentable and good condition, which is necessary for smooth and efficient running of the business of the assessee. Moreover, the expenditure incurred on account of repairs and maintenance of office building did not bring any capital asset into existence. Hence it was submitted that a plausible view has been taken by the ld AO in this regard in the light of various decisions and accordingly the same cannot be subject matter ....
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....d in law and in the circumstances of the case, the Ld. Pr. CIT erred in assuming jurisdiction under section 263 of the Act without satisfying the pre-conditions necessary for assumption of such jurisdiction i.e. an error in assessment order must be an error of law or fact. 3. On the facts and circumstances of the case and in law, the Ld. Pr. CIT erred in invoking his jurisdiction under section 263 of the Act on an issue which has been already considered by the Assessing Officer while completing the assessment order dated 20 May 2014 under section 143(3)/144C of the Act. 4. On the facts and in law and in the circumstances of the case, the Ld. Pr. CIT erred in passing the order under section 263 of the Act on the basis of mere conjectur....
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....ut foreign exchange loss. The ld AR argued that the ld AO had gone through the same and had made disallowance of the foreign exchange loss while completing the assessment. Hence it should be deemed that the ld AO had duly examined the other points included in the said notes which admittedly included note on repairs and maintenance of buildings. In fact the ld AO called for details of all expenses debited to profit and loss account. The assessee in response thereon requested the ld AO to call for specific items of expenditure which required examination as filing of details of all expenditure debited in profit and loss account would be very voluminous. Thereafter the ld AO did not call for any specific items of expenditure for examination. He....
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....irs and maintenance of buildings. Infact the ld AO called for details of all expenses debited to profit and loss account at the initial stage of assessment proceedings. The assessee in response thereon requested the ld AO to call for specific items of expenditure which required examination as filing of details of all expenditure debited in profit and loss account would be very voluminous. Thereafter the ld AO did not call for any specific items of expenditure for examination. The reliance placed by the ld AR on the note filed along with computation of total income would not come to the rescue of the assessee as admittedly the said note did not contain any break up of repairs and maintenance so as to warrant further examination by the ld AO.....