ANTONY LARA ENVIRO SOLUTIONS PRIVATE LIMITED ,MUMBAI vs. PCIT- 1 , THANE

ITA 3505/MUM/2025Status: DisposedITAT Mumbai26 November 2025AY 2020-21Bench: SHRI OM PRAKASH KANT (Accountant Member), SHRI RAJ KUMAR CHAUHAN ( (Judicial Member)10 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that the PCIT's assumption of jurisdiction under Section 263 was unwarranted. Since the foundational transition amount was thoroughly examined in a previous assessment year, and the current year's calculation was a mere apportionment, the Assessing Officer's assessment was not erroneous.

What were the facts?

The PCIT invoked Section 263 to revise an assessment order, believing the assessee had erroneously computed a transition amount for MAT purposes. The assessee argued that the issue was already scrutinized in a prior year and the current year's calculation was a mechanical apportionment.

What were the issues?

Whether the PCIT correctly invoked Section 263 when the Assessing Officer had already examined the core issue in a prior assessment year and the current year's treatment was a mechanical apportionment.

Which sections of the Income-tax Act were involved?

Section 263,Section 115JB(2C)

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, MUMBAI BENCH “A” MUMBAI

Before: SHRI OM PRAKASH KANT & SHRI RAJ KUMAR CHAUHAN

For Appellant: Mr. Bhupendra Shah, Mr. Rajesh Kumar Yadav, CIT-DR
Hearing: 26/11/2025

PER OM PRAKASH KANT, AM

This appeal by the assessee is directed against order dated 27.03.2025 passed by the Ld. Principal Commissioner of Income- tax – 1, Thane [in short ‘the Ld. PCIT’] for assessment year 2020-21, raising grounds as reproduced below:

A] Grounds

1.

In the facts of the case and in Law, the learned PCIT erred in invoking Section 263 to the case of the Appellant only by way of Antony Lara Enviro Solutions Pvt. Ltd. Antony Lara Enviro Solutions Pvt. Ltd. the A.O. and also by disregarding the detailed submissions the A.O. and also by disregarding the detailed submissions the A.O. and als

The order continues below.

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