PCIT v. Ramchandra Dahyabhai Narrow Fab (P.) Ltd. [2023] 155 taxmann.com 431/(2024) 296 Taxman 64 (Guj)(HC)

S. 263 : Commissioner-Revision of orders prejudicial to revenue-
Unexplained expenditure-Ad-hoc addition made by the Assessing Officer-Order of Tribunal quashing the direction of PCIT to do de novo assessment is affirmed. [S.69C, 26A]

Assessee’s case selected for scrutiny assessment. AO passed order and made additions for disallowance of EPF contribution and ad hoc disallowance of 20 per cent of expenses. Pr. CIT, exercising his jurisdiction u/s 263 set aside the assessment order and directed for fresh assessment. Tribunal quashed the order of the Pr. CIT.  Dismissing the appeal of the Revenue the Court held that   the Pr. CIT has not disputed the existence of the parties and the purchases made or commission paid. No contrary evidence was placed on record to substantiate that the purchases made or commission paid is bogus. Therefore, substantial question of law was raised and the appeal was dismissed. (AY. 2014-15)