2021 (10) TMI 670

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....krishna, CIT-DR and Sunku Srinivas, Sr. DR ORDER Per S.S. Godara, JM These assessee's appeals for AY. 2012-13 arise against the Pr. CIT-3 & CIT(A)-6, Hyderabad's order(s) dated 18-11-2016 & 13-03-2019 in appeal Nos. 10/Pr. CIT-3/263/16-17 & 10098/2017-18/A3/CIT(A)-6, involving proceedings u/s. 143(3) (in former appeal) and u/s. 143(3) r.w.s. 263 (in latter appeal) of the Income Tax Act,....

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....hold that the assessee had derived interest income of Rs. 44,84,828/- on the fixed deposits made with the Karur Vysya Bank, Hyderabad followed by its claim of administrative expenditure, financial costs and depreciation etc. to the tune of Rs. 1,87,311/-, Rs. 2,853/- and Rs. 44,46,552/-; respectively totalling to Rs. 46,36,716/-. The PCIT holds that the said three heads of expenses are in the natu....

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....rent qua its latter two heads of financial costs; including that directly paid to the bank of Rs. 2,8,53/- (supra) pertains to the very account only as well as the fact that the impugned depreciation/amortization has been a continuing relief granted very well from the preceding assessment years, whose facts and figures are nowhere in dispute. Coupled with this, the assessee has also filed on reco....

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.... has not taken one of the two possible views; as the case may be. We draw strong support therefrom and reverse the learned PCIT's action exercising Section 263 revision jurisdiction. The impugned Section 143(3) regular assessment dt. 16-03-2015 stands revived as the necessary corollary therefore. The assessee's instant Section 263 appeal ITA No. 557/Hyd/2018 is accepted. 5. Same order to....