AMBER ENTERPRISES INDIA LIMITED, RAJPURA,PATIALA vs. THE PRINCIPAL COMMISSIONER OF INCOME TAX, PATIALA, PATIALA

ITA 841/CHANDI/2026Status: DisposedITAT Chandigarh09 September 2026AY 2022-2314 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that the Pr. CIT failed to establish that the AO's order was erroneous or prejudicial to the revenue. The AO had conducted enquiries and accepted a plausible view presented by the assessee, which could not be substituted by the Pr. CIT's own view.

What were the facts?

The assessee's assessment order accepted returned income, but the Pr. CIT initiated revision proceedings under Section 263, citing inadequate enquiry regarding the difference between turnover in financial statements and GST returns, specifically concerning inter-unit sales. The assessee argued that these were stock transfers and reconciled the figures to the satisfaction of the AO.

What were the issues?

Whether the Pr. CIT was justified in invoking revisionary powers under Section 263 when the Assessing Officer had made adequate enquiries and accepted a plausible view presented by the assessee regarding turnover reconciliation.

Which sections of the Income-tax Act were involved?

Section 263,Section 147,Section 144B

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, “A” BENCH, CHANDIGARH

Before: HON’BLE SHRI LALIET KUMAR, JM & HON’BLE SHRI MANOJ KUMAR AGGARWAL, AM

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, Patiala (Pr. CIT) for Assessment Year (AY) 2022-23 vide impugned order dated 27-03-2026 proposing revision of an assessment as framed by Ld. Assessing Officer [AO] u/s.147 r.w.s. 144B of the Act on 23-03-2024 accepting the returned income of the assessee.

2.

The Ld. AR advanced arguments supporting the assessm

The order continues below.

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