2022 (4) TMI 93

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.... is an appeal filed by the assessee against the order of the Pr. CIT, Kochi-1, u/s. 263 of the Income Tax Act, 1961 (Act), dated 17-06-2020 for the AY. 2012-13. 2. Sri P.M. Veeramani, CA appeared on behalf of the assessee and Sri Shantham Bose, CIT-DR appeared on behalf of Revenue. 3. It was the submission by the Ld. AR that the issue raised by the Ld. Pr. CIT was in respect of the employees PF ....

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....he revision u/s. 263 of the Act. It was the submission that at the outset, the AO had considered the issue and had taken a conscious decision and consequently the issue cannot be a subject matter of revision u/s. 263 of the Act. It was the further submission and the fact that there are multiple decisions both against and in favour of assessee on this issue, shows that the issue is debatable issue ....

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....ws it to be a debatable issue. It was the prayer that order passed u/s. 263 of the Act may be quashed. 4. In reply, the Ld. DR vehemently supported the order of the Ld. Pr. CIT. It was the submission that the payments of the employees' contribution has not been made within the time prescribed under the relevant PF and ESI statutes. It was the submission that the assessee has made undue profit....