2025 (12) TMI 738

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....rtik Chokshi, AR For the Respondent : Shri Alpesh Parmar, CIT-DR ORDER Per Sanjay Garg, Judicial Member: The present appeal has been preferred by the assessee against the revision order passed by the Principal Commissioner of Income Tax, Ahmedabad-1 (hereinafter referred to as "PCIT") dated 12/03/2024 u/s. 263 of the Income Tax Act, 1961 (hereinafter referred to as "the Act") for the A....

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....ngs. 3. The Ld. Counsel further brought to our attention to the following Chart: Remarks Sr. No. Expense Amt on which TDS deducted Amt Debited to P&L Account 1. Royalty 84,70,80,028 83,46,52,368 2. Prof Fees 49,53,72,108 15,80,07,108 3. Com & Brokerage 82,77,25,926 97,53,77,504   Total 217,01,78,062 196,80,36,980   P....

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....wever, claimed as expenditure during the year under consideration and similarly TDS was deducted on certain advance payments made during the year under consideration, which will be claimed as an expenditure when the transaction is matured in the subsequent year. It was also explained that the loans were taken by the assessee through banking channel and that there was a clerical mistake in the Audi....