NARINDER SINGH, CHANDIGARH,CHANDIGARH vs. THE PCIT-1 CHANDIGARH, CHANDIGARH

ITA 1002/CHANDI/2025Status: DisposedITAT Chandigarh22 September 2026AY 2021-20224 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that once an assessment has attained finality through the Vivad Se Vishwas Scheme, it cannot be disturbed under Section 263. The settlement under the scheme conclusively settles disputes and prevents subsequent reopening.

What were the facts?

The assessee's income was assessed by the AO, who doubted purchases and made an addition. Subsequently, the Pr. CIT initiated revision proceedings under Section 263, considering the entire turnover as unexplained income. However, the assessee had opted for the Vivad Se Vishwas Scheme before the revision notice was issued.

What were the issues?

Whether a revisionary order under Section 263 can be passed when the assessment has been finalized under the Vivad Se Vishwas Scheme. Whether the settlement under the scheme bars subsequent revisionary proceedings.

Which sections of the Income-tax Act were involved?

Section 263,Section 143(3),Section 144B,Section 69A,Section 115BBE

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, “B” BENCH, CHANDIGARH

Before: HON’BLE SHRI MANOJ KUMAR AGGARWAL, AM & HON’BLE SHRI RAJESH DAMODARLAL SHARMA, JM

Manoj Kumar Aggarwal (Accountant Member)

1.

By way of this appeal, the assessee assails invocation of revisionary juri iction u/s 263 by Ld. Pr. Commissioner of Income Tax, Chandigarh-1 (Pr. CIT) for the Assessment Year (AY) 2021-22 vide impugned order dated 08.03.2025 proposing revision of an assessment as framed by Ld. Assessing Officer [AO] u/s 143(3) r.w.s. 144B of the Act on 27.12.2022. Having heard rival submissions, the appeal is disposed-off as under. The registry has noted delay of 69 days in the appeal

The order continues below.

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