BURGESS ENGLISH SENIOR SECONDARY SCHOOL, BILASPUR,BILASPUR vs. PCIT, RAIPUR-1, RAIPUR

ITA 449/RPR/2025Status: DisposedITAT Raipur21 September 2026AY 2015-1621 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that the revisionary order under Section 263 was not sustainable as the Principal CIT had not conducted sufficient inquiry or recorded specific findings to justify the order. The Tribunal also noted the principle of consistency followed in the assessee's own case for a prior assessment year.

What were the facts?

The assessee's appeal was filed 54 days late, but the delay was condoned. The assessee was aggrieved by a revisionary order passed under Section 263 of the Income Tax Act, 1961, which held the assessment order to be erroneous and prejudicial to the revenue.

What were the issues?

Whether the revisionary order passed under Section 263 was justified without proper inquiry and specific findings by the Principal CIT. Whether the principle of consistency should be applied regarding the assessee's claim of being part of the Chhattisgarh Diocese Board.

Which sections of the Income-tax Act were involved?

Section 263

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, RAIPUR BENCH, “DB” RAIPUR

Before: SHRI R.K PANDA & SHRI PARTHA SARATHI CHAUDHURY

For Appellant: Shri Sunil Kumar Agrawal, CA, Ms. Vidya Verma, Advocate
For Respondent: Shri Rituparna Namdeo, CIT-DR
Hearing: 11.08.2026Pronounced: 21.09.2026

PER PARTHA SARATHI CHAUDHURY, JM: The present appeal preferred by the assessee emanates from the order of the Ld.Pr. CIT, Raipur-1, dated 13.03.2025 for the assessment year 2015-16 as per the grounds of appeal on record.

2.

At the very outset, it is noted that the appeal is time barred by 54 days. Explaining the reasons for such delay and praying for condonation, the assessee had filed an “affidavit”, dat

The order continues below.

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