2026 (5) TMI 1494

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.... For Appellant(s) : Mr. K.K. Bissa For Respondent(s) : -- ORDER: 1. The challenge in this appeal is to the order dated 24.12.2024 passed by the Income Tax Appellate Tribunal (in short, "the ITAT"), whereby it has quashed the order passed by the Principal Commissioner of Income Tax (in short, "the PCIT") under Section 263 of the Income tax Act, 1961 (in short, "the Act") holding that the ....

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.... (Bom)]. 3. In the present case, we notice that the ITAT found that in the assessee's own case of assessment year 2008-09, a co-ordinate jurisdiction Bench held as under:- "...6.2 ... In the assessee's own case for Assessment Year 2008-09 (ITA No. 366/Jodh/2015), the Coordinate Jurisdiction Bench has dismissed the department's appeal and upheld that provisions for doubtful debts consti....

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....urt in "The Commissioner of Income Tax 7 v. M/s. Paville Projects Pvt. Ltd."[ 2023 LiveLaw (SC) 282], however, we find that the facts in the said case as mentioned in para 4.1 reflects that the AO's had allowed expenses of 31.05 crores while computing the capital gain from the sale of the land whereas the payments were actually made to shareholders which cannot fall within the definition of expens....