Raunaq EPC International Ltd. Vs PCIT(Central)

Parties Involved

Facts Summary

This appeal by Raunaq EPC International Ltd. for Assessment Year 2018-19 arises against the PCIT(Central), Delhi-1’s order dated 11.03.2024, in proceedings under section 263 of the Income Tax Act, 1961. The assessee challenges the revision order enhancing income by Rs. 19,04,090/- under section 263 and disallowing employees' contribution under section 36(1)(va) of Rs. 46,20,366/-. The assessee argues that no expenses were incurred for managing investments and there was no movement in the shares invested during AY 2018-19. Additionally, the assessee contends that the disallowance of employees' contribution had reached finality at the time of original assessment proceedings.…

Legal Issues

• 1. Whether the PCIT erred in law by enhancing income under section 263 and applying section 14A without considering the absence of expenses incurred by the assessee.
• 2. Whether the PCIT erred in law by disallowing employees' contribution under section 36(1)(va).

Judgment Outcome

Decided in favour of Assessee.

Precedents Relied Upon

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