2025 (8) TMI 1277

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..... Commissioner of Income Tax (Appeals), Delhi - 36 ["ld. CIT(A)", for short] dated 22.09.2020 for AY 2014-15 and the assessee has filed cross objections against the impugned order dated 22.09.2020 for AY 2014-14. The assessee has also filed appeal against the order of Pr. CIT, Delhi-9 dated 05.02.2018 for AY 2014-15 passed u/s 263 of the Income-tax Act, 1961 (for short 'the Act'). 2. Since the issues are common and the appeals are connected, therefore, the same are heard together and being disposed off by this common order. 3. Brief facts relating to the appeals preferred by the Revenue and assessee and cross objections filed by the assessee are, Ld. PCIT had initiated the proceedings u/s 263 of the Act after verification of assessmen....

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.... being paid to directors and other senior employees. 4. Further he observed that the AO has not verified the above aspects in his order, however, he further observed at para 6 of the impugned order that it is apparent, the reasons for decrease in profits were asked by the AO and assessee vide its reply dated 25.04.2016 submitted the relevant information like Balance Sheet and details of related party transactions. The assessee also explained the reasons for drop in the profit margin. The main reasons for drop of the profit margin observed by the PCIT was on two issues, first time payment of professional fees to its related parties and depreciation claimed on the construction of workshop in Gurgaon. After analysing the above aspect in det....

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....efer to deal with the issues under consideration as under :- 7. Professional fees paid to the Associated Enterprises, we observe that with regard to the issue under consideration, the relevant information was already collected and verified by the Assessing Officer and the same was already confirmed by Ld PCIT at para 6 of the impugned order. The assessee also submitted the relevant information as called for by the AO. The AO chose not to discuss the above issues in his order, however he has collected the information and after verification, he was convinced with the submissions and allowed the same in favour of the assessee, in our view, may be AO has taken a possible view. In revision proceedings, Ld PCIT was not satisfied with the findi....