ARJUN SINGH,PALWAL vs. WARD 1(1), FBD, FARIDABAD
What did the Tribunal hold?
The tribunal found that its earlier order had already reversed the PCIT's Section 263 revision directions, which formed the sole basis for the impugned consequential assessment. Therefore, the tribunal held that the consequential assessment had no legal standing and quashed it.
What were the facts?
The Assessing Officer made a long-term capital gains addition of Rs. 9.50 crore in a consequential assessment under Section 143(3) r.w.s. 263, which was upheld by the CIT(A). This assessment was framed based on a PCIT's revision order under Section 263.
What were the issues?
The key legal issue was the validity of a consequential assessment framed under Section 143(3) r.w.s. 263, when the underlying Section 263 revision order had already been set aside by the ITAT.
Which sections of the Income-tax Act were involved?
AI-generated summary — verify with the full judgment below
Income Tax Appellate Tribunal, DELHI BENCH ‘G’, NEW DELHI
Before: SHRI SATBEER SINGH GODARA & SHRI SANJAY AWASTHI
IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH ‘G’, NEW DELHI
BEFORE SHRI SATBEER SINGH GODARA, JUDICIAL MEMBER AND SHRI SANJAY AWASTHI, ACCOUNTANT MEMBER ITA No. 6487/Del/2026 Assessment Year: 2013-14 Arjun Singh Vs Ward 1(1), FBD, House No. 1014, Prithla, Palwal- C.R. Building, Faridabad, 121102 Haryana- 122001 (APPELLANT) (RESPONDENT) PAN No. EICPS8476L
Assessee by: CA Sikha Bansal & CA Charitra Gupta Revenue by : Shri Sher Singh, CIT(DR)
Date of Hearing: 09.09.2026 Date of Pronouncement: 23.09.2026 ORDER PER SATBEER SINGH GODARA, JM: This assessee’s appeal ITA No. 6487/Del/2026 for assessment year 2013-14, arises against the Commissioner of Income Tax (Appeals)/National Faceless Appeal Centre [in short, the “CIT(A)/NFAC”], Delhi’s DIN & Order No. ITBA/NFAC/S/250/2026-27/1088261406(1) dated 01.04.2026, involving proceedings u/s 147 of the Income-tax Act, 1961 (hereinafter referred to as ‘the Act’); respectively.
Heard both the parties. Case files perused.
We advert to the assessee’s sole substantive ground raised in the instant appeal that both the learned lower authorities have erred in law and on facts in making long term capital gains addition amounting to Rs.
9,50,00,000/-; in the Assessing Officer’s section 143(3) r.w.s. 263 assessment framed on 31.03.2022 which stands upheld in the CIT(A) lower appellate discussion.
That being the case, we sought to know the final status of the assessee’s appeal; if any, preferred against the learned PCIT’s section 263 revision directions dated 17.03.2021. We are informed that this tribunal in his appeal ITA No. 5475/Del/2025 decided on 30.04.2026 has already reversed the learned PCIT’s revision directions forming the sole basis on the learned Assessing officer’s impugned consequential assessment. This being the clinching factual position going unrebutted from the Revenue side, we are of the considered view that the impugned consequential assessment proceedings have no legs to stand which are hereby quashed in very terms therefore. No other ground or argument has been pressed.
This assessee’s appeal is allowed.
Order is pronounced in open court on 23.09.2026.
Sd/- Sd/- (SANJAY AWASTHI) (SATBEER SINGH GODARA) ACCOUNTANT MEMBER JUDICIAL MEMBER Dated: 23.09.2026 *Pooja Mittal, Sr. PS* Copy forwarded to: 1. Appellant 2. Respondent 3. CIT 4. CIT(Appeals) 5. DR: ITAT ASSISTANT REGISTRAR
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