BYRAPURA GOWDE GOWDA DEEPU,BANGALORE vs. DCIT CENTRAL 3(1), BANGALORE

ITA 2540/BANG/2026Status: DisposedITAT Bangalore16 September 2026AY 2023-2422 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that the AO had conducted sufficient enquiries and applied his mind, making a substantial addition. The PCIT's disagreement with the extent of enquiry was not sufficient to revise the assessment order under Section 263.

What were the facts?

Following a search, the assessee's assessment for AY 2023-24 was completed with an increased income. The PCIT initiated revision proceedings under Section 263, citing inadequate enquiry by the AO regarding seized documents and transactions.

What were the issues?

Whether the PCIT correctly invoked Section 263 powers when the AO had conducted enquiries and made additions, and whether the assessment order was erroneous and prejudicial to revenue.

Which sections of the Income-tax Act were involved?

Section 263,Section 132,Section 143(3),Section 132(4),Section 131(1),Section 133(6)

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, BANGALORE BENCHES, BANGALORE

Before: SHRI WASEEM AHMED & SHRI SOUNDARARAJAN K.

For Respondent: Shri. Somnath Ukkali, CIT

PER SHRI WASEEM AHMED, ACCOUNTANT MEMBER:

The present appeal has been instituted by the assessee against the order of the Principal Commissioner of Income Tax, Central Bangalore (in short “Ld. PCIT”) passed under section 263 of the Income Tax Act, 1961 (in short “Act”) for the assessment year 2023-24. 2. In the memo of appeal, the assessee has raised 1

The order continues below.

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