Held that there was an adjustment of prior period expenses in the statement showing reconciliation of equity from the previous generally accepted accounting principles to Indian Accounting Standards. This adjustment in the balance-sheet and not in the profit and loss account needed further verification. Prima facie, the Principal Commissioner had sufficient grounds to form an opinion that the order had been passed by the Assessing Officer without making inquiries or verification which should have been made. Considering the facts and the quantum at issue, the Principal Commissioner had properly assumed jurisdiction under section 263. That that the Principal Commissioner had not disallowed the claim but had set aside the assessment order passed by the Assessing Officer and directed him to pass a fresh assessment order to the extent of the issue, after allowing adequate opportunity of being heard to the assessee. The order of the Principal Commissioner is affirmed. (AY.2018-19)
Inductotherm (India) P. Ltd. v. PCIT (2024)112 ITR 59 (SN)(Ahd)(Trib)
S. 263 : Commissioner-Revision of orders prejudicial to revenue-Excess provision of Corporate Social Responsibility expenses of earlier years should have been first written back to profit and loss account and not in Balance-Sheet-No discussion in the assessment order-Revision is justified. [S. 143(3)]
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