PCIT v. Prince Water House (2020) 270 Taxman 307 (Cal.)(HC)

S. 263 : Commissioner-Revision of orders prejudicial to revenue-Risk Policy Premium-Revision barred by limitation-Order of Tribunal is affirmed. [S. 37(1)]

Assessee claimed deduction on account of Accountants Risk Policy Premium paid by it. Assessing Officer passed order, dated 31-12-2009, allowing claim of assessee. On 27-3-2017, Commissioner passed order under section 263 setting aside order passed by Assessing Officer and directed Assessing Officer to pass fresh order after enquiry in respect of allowability of Accountants Risk Policy Premium. On appeals, Tribunal quashed order passed under section 263 holding that same was barred by limitation. High Court affirmed the order of the Tribunal. (AY.  2007-08)