2024 (9) TMI 213

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....eeling aggrieved by revision-order dated 26.03.2024 passed by learned Pr. Commissioner of Income-Tax (Central), Bhopal ["PCIT"] u/s 263 of Income-tax Act, 1961 ["the Act"] which in turn arises out of assessment-order dated 30.03.2022 passed by learned ACIT, Central, Bhopal ["AO"] u/s 153C r.w.s. 143(3) of the act for Assessment-Year ["AY"] 2014-15, the assessee has filed this appeal on the grounds....

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....t is prejudicial to the interest of revenue which attracts revisionary-jurisdiction u/s 263. Accordingly, the PCIT issued show-cause notice dated 05.01.2024 and finally passed revision-order dated 26.03.2024. Aggrieved by such revision-order, the assessee has come in this appeal before us. 3. Ld. AR for assessee carried us to revision-order and demonstrated that there is one single issue for whic....

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....is rendered erroneous-cum-pre-judicial to the interest of revenue warranting revisionary action u/s 263. 4. We have heard learned Representatives of both sides peacefully and considered their submissions and perused the impugned order in the light of applicable provisions of Income-tax Act. 5. On a careful consideration, we find that the PCIT has revised the assessment-order of AY 2014-15 passed....

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....153C as per landmark judgement of Hon'ble apex court in PCIT Vs. Abhishar Buildwell Pvt. Ltd. (2023) 454 ITR 212 (SC). The facts of case shows that the PCIT has revised AO's order for the issue of disallowance of excessive interest paid by assessee on loans taken in comparison to the interest received on loans given. The issue raised by PCIT does not emanate from any of the incriminating material ....