Tribunal set aside the order of the revision order of the Commissioner on the ground that in instant case limited scrutiny was in respect of excess liability shown and disallowance under section 40A(3), whereas show cause notice under section 263 was regarding FIFO method of valuation of closing stock adopted by assessee and these were unconnected issues, assessment order could not be held to be erroneous and prejudicial to interest of revenue when Assessing Officer could not have travelled beyond issues forming subject matter of limited scrutiny. Order of Tribunal quashing the revision order is affirmed.(AY. 2014-15)
PCIT v. Shark Mines and Minerals (P.) Ltd. (2024) 470 ITR 76 /151 taxmann.com 71 (Orissa) (HC) Editorial: Shark Mines and Minerals (P.) Ltd v. PCIT (2014) 117 ITR 67 (Cuttack)(Trib)
S. 263 : Commissioner-Revision of orders prejudicial to revenue-limited scrutiny-Method of accounting-When the Assessing Officer could not have possibly examined issue which is not subject matter limited scrutiny-Commissioner cannot revise the order-Order of Tribunal is affirmed. [S.40A((3), 145, 260A]
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