MANDALA SUBRAMANYAM,SRIKALAHASTI vs. ITO., WARD-1(3), TIRUPATI

ITA 974/HYD/2025Status: DisposedITAT Hyderabad23 September 2026AY 2017-1814 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that the PCIT's assumption of jurisdiction under Section 263 was unsustainable as the AO had made a conscious decision after considering the assessee's explanation. The AO's order was not erroneous or prejudicial to revenue.

What were the facts?

The assessee received property sale consideration in cash, violating Section 269SS. The Assessing Officer initially dropped penalty proceedings under Section 271D. The PCIT invoked Section 263, setting aside the AO's order, stating it was erroneous and prejudicial to revenue.

What were the issues?

Whether the PCIT was justified in invoking revisionary jurisdiction under Section 263 when the Assessing Officer had made a conscious decision after due verification and consideration of assessee's explanation.

Which sections of the Income-tax Act were involved?

Section 269SS,Section 271D,Section 263,Section 143(2),Section 143(3)

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, Hyderabad ‘A‘ Bench, Hyderabad

Before: Shri Ravish SoodShri Madhusudan Sawdia

Hearing: 06/08/2026

Per Madhusudan Sawdia, A.M.:

This appeal is filed by Shri Mandala Subramanyam (“the assessee”), feeling aggrieved by the order passed by the Learned Principal Commissioner of Income Tax, Tirupati (“Ld. PCIT”), dated 26.03.2025 for the A.Y. 2017-18. 2. The assessee has raised the following grounds of appeal:

3.

The brief facts of the case are that the assessee is an individual, filed his return of income for the Assessment Year 2017-18 on 22.08.2017. The case of the assessee was selected for limited scrutiny and, accordingly, notice under section 143(

The order continues below.

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