PCIT v. Brahma Centre Development Pvt. Ltd. (2021) 437 ITR 285 / 205 DTR 249/ 323 CTR 888(Delhi) (HC)

S. 263 : Commissioner-Revision of orders prejudicial to revenue-Two possible view-Interest on fixed deposit-Order of revision is not valid. [S.143(3)]

Dismissing the appeal the Court held that   the Assessing Officer having received a response to his query about the adjustment of interest against inventory, in the assessment years in question, concluded that there was a nexus between the receipt of funds from investors located abroad and the real estate project, which upon being invested generated interest. Thus, it could not be said that the conclusion arrived by the Assessing Officer, that such adjustment was permissible in law, was erroneous. The order of revision was not valid. (AY.2012-13, 2013-14)