Held that AO having conducted detailed enquiries into assessee’s claim of deduction under s. 35(2AB) and arrived at the conclusion that apportionment of R&D expenditure incurred by the assessee-company to its Assam Unit is not required, Principal CIT has no authority to substitute his views by invoking his revisionary powers under s. 263 of the Act. It trite law that revisionary power cannot be exercised merely because the revisionary authority holds a view different than that taken by the lower authority (AY. 2018-19)
Anabond Ltd. v. PCIT (2025) 233 TTJ 761 / 246 DTR 32 (Chennai)(Trib)
S. 263 : Commissioner-Revision of orders prejudicial to revenue-Expenditure on scientific research-Conducted detailed enquiries into claim of deduction-Revision order is quashed. [S. 35(2AB), 143(3)]
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