ARVIND ADVANCED MATERIALS LIMITED (FORMERLY KNOWN AS ARVIND TRUE BLUE LIMITED),AHMEDABAD vs. THE PCIT, AHMEDABAD-1, AHMEDABAD

ITA 1015/AHD/2025Status: DisposedITAT Ahmedabad18 September 2026AY 2021-2214 pages
AI SummaryDismissed

What did the Tribunal hold?

The Tribunal held that the PCIT validly invoked Section 263 jurisdiction as the AO's inquiry was not adequate. The assessment order was deemed erroneous and prejudicial to the revenue due to the failure to properly examine the commission expenditure and TDS liability.

What were the facts?

The PCIT invoked Section 263 powers to revise an assessment order, citing the assessee's failure to deduct TDS on commission expenses and the Assessing Officer's lack of adequate inquiry. The assessee argued that the amount was discount, not commission, and that the AO had already inquired into the matter.

What were the issues?

Whether the PCIT validly exercised revisionary powers under Section 263 due to inadequate inquiry by the AO regarding TDS on commission expenses. Whether the expenditure was commission or discount.

Which sections of the Income-tax Act were involved?

Section 263,Section 143(3),Section 144(B),Section 40(a)(ia),Section 41(1)

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, AHMEDABAD BENCHES, AHMEDABAD

Before: SHRI NARENDRA PRASAD SINHA & SHRI SANJAY KUMAR

Pronounced: 18.09.2026

PER SANJAY KUMAR, JUDICIAL MEMBER:

- This appeal has been filed by the Assessee against the order dated 25.03.2025 passed by the Ld. Principal Commissioner of Income Tax, Ahmedabad-1 (hereinafter referred to as ‘Ld. PCIT’ in short), under Section 263 of the Income-tax Act, 1961 (hereinafter referred to as ‘the Act’ in short) for Assessment Year 2021-22. 2. The Assessee has raised following grounds of Appe

The order continues below.

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