Dismissing the appeal of the Revenue the court held that the Assessing Officer had raised specific query with regard to job work charges and assessee had also filed party-wise details concerning relevant bills and vouchers including payment made through account payee cheques, withholding of tax and confirmation from concerned parties. Mere failure to issue notice under section 133(6) did not warrant exercise of jurisdiction under section 263 of the Act. Order of Tribunal quashing the revision order is affirmed. (AY. 2015-16)
PCIT v. R.K. Jain Infra Projects (P.) Ltd. (2023) 293 Taxman 465 /(2024) 464 ITR 555(Delhi)(HC)/Editorial: SLP of Revenue is dismissed , PCIT v. R.K. Jain Infra Projects (P.) Ltd ( 2024) 297 Taxman 369 /464 ITR 584( SC)
S. 263 : Commissioner-Revision of orders prejudicial to revenue-Business expenditure-Specific query was raised in the original assessment proceedings-Mere failure to issue notice under section 133(6) did not warrant exercise of jurisdiction under section 263 of the Act-Order of Tribunal is affirmed.[S. 37(1), 143(3)]