ECO CHEM SALES & SERVICES,SURAT vs. CIRCLE 1(3), SURAT

ITA 324/SRT/2025Status: DisposedITAT Surat18 August 2026AY 2020-2113 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that the AO had conducted sufficient inquiry by issuing notices and considering the assessee's detailed replies and documents. The PCIT's revision was based on general information about political parties and lacked specific adverse material linking the assessee. Therefore, the revision order was unsustainable.

What were the facts?

The assessee claimed deduction under Section 80GGC for donations made to political parties. The Principal Commissioner of Income-Tax (PCIT) initiated revision proceedings under Section 263, alleging the Assessing Officer (AO) failed to conduct proper inquiry. The PCIT believed the donations were bogus and the assessment order was erroneous and prejudicial to revenue.

What were the issues?

Whether the PCIT validly invoked Section 263 when the AO had made sufficient inquiries and there was no specific adverse material against the assessee. Whether the assessment order was erroneous and prejudicial to the interest of revenue due to alleged lack of inquiry.

Which sections of the Income-tax Act were involved?

Section 263,Section 143(3),Section 80GGC

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, SURAT BENCH, SURAT

Before: MS. SUCHITRA KAMBLE & SHRI B.M. BIYANI

For Appellant: Shri Umesh Dalal, CA
For Respondent: Shri Ravi Kant Gupta, CIT(DR)
Hearing: 10.06.2026Pronounced: 18.08.2026

Per B.M. Biyani, A.M.:

Feeling aggrieved by the revision-order dated 18.02.2025 passed by learned Pr. Commissioner of Income-Tax, Surat-1 [“Ld. PCIT”] u/s 263 of Income-tax Act, 1961 [“the Act”], which in turn arises out of the assessment-order dated 22.09.2022 passed by learned Assessment Unit of Income-tax Department Eco Chem Sales & Services

[“Ld. AO”] u/s 143(3) r.w.s. 144B of the act for Assessment-Year [“AY”] 2020- 21, the assessee has filed this appeal on following grounds:

“1. On the facts and circumstances of the case, the learned Pr. CIT has erred in invoking provisions of section 263.

The order continues below.

Read the full judgment

A free account opens 10 full judgments a month. Re-reading one you have already opened does not count again.

Create a free accountSign in

See plans and prices

The summary, the parties, the sections and the citations above are open to everyone and always will be. Only the text of the order and the PDF are metered.

More judgments on Section 263

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

Recent GST High Court judgments

Search GST case law →