MAD Studios Pvt. Ltd. v. PCIT (2021) 88 ITR 37 (SN) (Mum.)(Trib.)

S. 263 : Commissioner-Revision of orders prejudicial to revenue-Issue subject matter of appeal-Commissioner is not barred from exercising power of revision-Interest free funds-Direction was modified-Failure to deduct ta at source-Production expenses-Revision was held to be valid. [S. 36(1)(iii), 40(a)(ia), 263, Expln. 1(c)]

Held that Commissioner is not barred from exercising power of revision though the issue is subject matter of appeal before CIT(A). As regards utilization of interest free funds, the direction of the Commissioner was modified.  In respect of failure to deduct tax at source in respect of production expenses.  Revision was held to be valid. (AY.2013-14, 2014-15)