Shanti Prime Publication Pvt. Ltd.
Section 263 of the Income Tax Act, 1961 — Revision — The Principal Commissioner was not justified in invoking the jurisdiction under section 263 or to hold that the assessment order was erroneous or prejudicial to the interests of revenue as the reason for difference between the amount shown in Form 26AS and that shown in the return was because the interest received from the banks that was duly accounted for and considered in the financial statements of the assessee and was adjusted against the project expenditure and during the assessment proceedings when the AO proposed to charge the interest to tax. the very same explanation had been offered by the asseasee and accepted by the AO, therefore, it was not a case of no enquiry and as a matter of fact, it was specifically brought to the notice of the AO that the interest earned was adjusted against the project Expenditure— Brahma Center Decelopment P. Ltd. vs. Principal Commissioner of income tax [2020] 77 ITR (trib) 156 (Delhi)