SHRI SAI SHIKSHAN SANSTHA,NAGPUR vs. PRINCIPAL COMMISSIONER OF INCOME TAX (CENTRAL), NAGPUR

ITA 79/NAG/2022Status: DisposedITAT Nagpur08 September 2026AY 2012-1339 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that the AO had conducted sufficient inquiries and accepted a plausible view regarding the loan transaction. The PCIT's revisionary powers under Section 263 were not justified as the AO's order was not demonstrably erroneous or prejudicial to revenue.

What were the facts?

The assessee trust received Rs. 2.27 crore from Zodiac Dealcom Pvt. Ltd., which was allegedly routed through multiple layers. The Assessing Officer (AO) initially accepted this as a loan after receiving confirmation from Zodiac Dealcom. The Principal Commissioner (PCIT) revised this order, deeming it erroneous and prejudicial to revenue, directing a fresh assessment.

What were the issues?

Whether the PCIT correctly invoked Section 263 to revise the AO's assessment order when the AO had conducted inquiries and arrived at a plausible conclusion regarding the genuineness of loan transactions.

Which sections of the Income-tax Act were involved?

Section 143(3),Section 147,Section 148,Section 263,Section 133(6),Section 119,Section 142(1)

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, “DB” BENCH, DELHI

Before: SHRI ANUBHAV SHARMA & SHRI KHETTRA MOHAN ROYShri Sai Shikshan Sanstha

Hearing: 19.06.2026Pronounced: 08.09.2026

PER ANUBHAV SHARMA, JM:

This appeal is preferred by the assessee against the order dated 31.03.2022 of the Ld. PCIT(Central), Nagpur (hereinafter referred as Ld. PCIT in short or ‘Ld. Revisionary Authority’) in DIN & Order No: ITBA/REV/F/REV5/2021-22/1042200884(1) arising out of the assessment order dated 29.11.2019 u/s 143(3) r.w.s 147 of the Income Tax Act, 1961

P a g e | 2 Shri Sai Shikshan Sanstha (AY: 2012-13) (hereinafter referred to as ‘the Act’) passed by ACIT, Exemption, Nagpur, (hereinafter referred to as ‘ld. AO’) for AY: 2012-13. 2. Heard and perused the records. The case of department is that assessee Shri Sai

The order continues below.

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