2025 (4) TMI 1720

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.... Dr. Arun Kumar Yadav - Ld. CIT-DR ORDER Manoj Kumar Aggarwal (Accountant Member) 1. By way of this appeal, the assessee assails invocation of revisionary jurisdiction u/s 263 by Ld. Pr. Commissioner of Income Tax-1, Agra (Pr.CIT) for Assessment Year (AY) 2018-19 vide impugned order dated 21-03-2023 in the matter of an assessment framed by Ld. AO u/s 143(3) of the Act on 01-02-2021. Havin....

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.... u/s 192. The Ld. Pr. CIT also opined that the provisions of Sec.40A(3) would be attracted. The assessee also claimed Business Promotion expenses of Rs.8.90 Lacs in cash and the assessee made huge cash withdrawals which should have been examined by Ld. AO. Accordingly, the assessee was show-caused. The assessee refuted all these allegations and stated that due enquiries were made on all the issues....

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....The details of all salaried employees were given along with ledger extracts. None of the payment exceeded the threshold limit of Rs.10000/-. On the issue of business expenses also, all details were furnished by the assessee to Ld. AO in its reply dated 09-12-2020 along with ledger extracts. The Ld. AO looked into the same and arrived at a satisfaction. In the light of all these facts, it could be ....

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....d in substituting the view of Ld. AO with that of his own view. Simply because some further verification was required or simply because the verification was not done in a particular manner, the same could not justify revision of the order unless it was shown that the view of Ld. AO was erroneous or opposed to any law. 4. The Hon'ble Supreme Court in Malabar Industrial Co. Ltd. vs. CIT (supra) h....