JADE CONSTRUCTIONS PRIVATE LIMITED,MUMBAI vs. PCIT-2, MUMBAI

PDF · subscribers
ITA 6292/MUM/2026Status: DisposedITAT Mumbai18 September 2026AY 2022-2319 pages

In favour of the assessee: the assessee's appeal was allowed. From the AI summary of this appeal.

AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that the PCIT's order was based on an incorrect premise that no enquiry was conducted and that the PCIT had enlarged the issues beyond the show-cause notice. The Tribunal found that the assessment order was not erroneous or prejudicial to the revenue.

What were the facts?

The assessee's assessment order was set aside by the Principal Commissioner of Income Tax (PCIT) under section 263, citing lack of adequate enquiry into unsecured loans, trade payables, and work-in-progress. The assessee argued that sufficient enquiries and documentation were provided during the assessment.

What were the issues?

Whether the PCIT correctly invoked revisionary powers under Section 263 due to alleged lack of enquiry by the Assessing Officer, and whether the PCIT travelled beyond the scope of the show-cause notice.

Which sections of the Income-tax Act were involved?

Section 263,Section 143(3),Section 144B,Section 69A,Section 133(6)

AI-generated summary — verify with the full judgment below

Before: SHRI AMIT SHUKLA & SHRI ARUN KHODPIA

For Appellant: Shri Bhupendra Shah
For Respondent: Shri Nishant Samaiya (CIT DR)
Hearing: 18.09.2026Pronounced: 18.09.2026

आदेश की प्रतितलतप अग्रेतिि/Copy of the Order forwarded to :

P a g e | 19 ITA No. 6292/Mum/2026 A.Y. 2022-23 Jade Constructions Private Limited 1. अपीलार्थी / The Appellant प्रत्यर्थी / The Respondent. 2. 3. आयकर आय क्त / CIT 4. दिभागीय प्रदिदनदि, आयकर अपीलीय अदिकरण DR, ITAT, Mumbai 5. गार्ड फाईल / Guard file. सत्यादपि प्रदि //True Copy// आदेशानुसार/ BY ORDER,

उप/सहायक पंजीकार (Dy./Asstt. Registrar) आयकर अपीलीय अतिकरण/ ITAT, Bench, Mumbai.

More judgments on Section 263

All 13,616 judgments and leading authorities on Section 263 →

Latest GST High Court judgments

Search GST case law →