AMAN HOLDINGS PVT LTD,NEW DELHI vs. PR.CIT - 1, DELHI

ITA 660/DEL/2021Status: DisposedITAT Delhi23 July 2025AY 2015-16Bench: SHRIS.RIFAUR RAHMAN (Accountant Member), SHRI SUDHIR PAREEK (Judicial Member)1 pages
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What did the Tribunal hold?

The Tribunal held that the assessment order was void ab initio due to want of jurisdiction as there was no valid order under Section 127 of the Act transferring jurisdiction. Consequently, the revision proceedings initiated under Section 263 were also quashed.

What were the facts?

The assessee's assessment order was passed by an Assessing Officer (AO) who allegedly lacked jurisdiction. The Principal Commissioner of Income-tax (PCIT) initiated revision proceedings under Section 263 against this assessment order. The assessee contended that the AO's jurisdiction was not validly transferred.

What were the issues?

Whether the assessment order was void due to lack of valid jurisdiction, and if so, whether the subsequent revision order under Section 263 is also bad in law.

Which sections of the Income-tax Act were involved?

Section 263,Section 143(3),Section 127,Section 56(2)(viia)

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Cases cited in this judgment(4)Show list

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Income Tax Appellate Tribunal, DELHI BENCH ‘F’: NEW DELHI

For Appellant: Ms. Meenal Goyal, CA, Shri Amon Parimoo, Advocate
For Respondent: Ms. Monika Singh, CIT DR
Hearing: 10.07.2025

PER S.RIFAUR RAHMAN, ACCOUNTANT MEMBER :

1.

This appeal is filed by the assessee against the order of ld. Principal Commissioner of Income-tax, Delhi-1 [hereinafter referred to as ‘ld. PCIT (A)] dated 31.03.2021 for Assessment Year 2015-16 passed under section 263 of the Income-tax Act, 1961 (for short ‘the Act’) raising following grounds of appeal :- “1. That on the facts and circumstances of the case, the order dated 31.03.2021 passed by the Pr.CIT Central I, Delhi ("Ld. Pr.CIT") the Income Tax Act, 1961 ("Act") cancelling the order dated 12.12.2017 passed u/s.143(3) by the ITO Ward 2(3), Delhi ("Ld. AO") and 2 directing the Ld. AO for a proposed addition uls.56(2)(viia) is void ab initio due to want of juri iction and is liabl

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