Dismissing the appeal of the assessee the Tribunal held that whether educational expenses of Director at abroad whether allowable or not requires greater scrutiny by the AO , hence the revision of the order was held to be valid, more over , explanation 2 to Section 263 is in place w.e.f 1-6 -2005 . ( AY. 2012-13 )
Hunumesh Realtors (P.) Ltd. v. PCIT (2018) 168 ITD 87 (Mum) (Trib.)
S. 263 : Commissioner – Revision of orders prejudicial to revenue – Educational expenses of director at abroad- Expenditure allowable or not requires greater scrutiny therefore revision was held to be justified [ S. 37(1) ]