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Defending revision proceedings for an Indian polymer manufacturer

Engagement: SKP was engaged by an Indian multinational polymer manufacturing company to defend the revision proceedings initiated by the Commissioner of Income Tax (CIT) under Section 263 of the Income Tax Act, 1961 (ITA).

Section 263 of the ITA confers the power upon the CIT to call for and examine the records of any proceeding under the Act and revise any order if he considers the same to be erroneous and prejudicial to the interests of the Revenue. The CIT may pass an order enhancing or modifying the assessment, or cancelling the assessment and directing a fresh assessment.

At the assessment stage, our tax team properly presented all facts to the concerned Assessing Officer, who was convinced and hence, no addition was made. Our team presented the merits of the case by gathering all relevant information, having detailed discussions with the management of the company and visiting the actual site for better presentation of the case. We defended the revision proceedings on the merits of the case and convinced the CIT to drop the proceedings.

Value Delivered
Our detailed and strong defence resulted in convincing the CIT to drop the proceedings, which is a rare phenomenon in the Indian tax regime. With our efforts, the client achieved tax savings of INR 160 million.