M/S GANESH PRASAD KHETAN, RAIPUR,RAIPUR vs. PCIT, RAIPUR-1, RAIPUR

ITA 430/RPR/2026Status: DisposedITAT Raipur06 August 2026AY 2022-2317 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that the Assessing Officer had conducted due verification regarding unsecured loans and taken a plausible view, thus the Pr. CIT could not assume revisionary jurisdiction merely due to a difference of opinion. Regarding business receipts, the Tribunal found that the Pr. CIT had not pointed out any defects in the reconciliation statement provided by the assessee, making the revisionary order a mere direction for a roving inquiry.

What were the facts?

The Principal Commissioner of Income Tax invoked revisionary jurisdiction under Section 263 of the Income Tax Act, 1961, against the assessment order. The revision was based on alleged suppression of business receipts and unverified unsecured loans, deeming the assessment order erroneous and prejudicial to the revenue.

What were the issues?

Whether the Pr. CIT's assumption of revisionary jurisdiction under Section 263 was justified when the Assessing Officer had conducted due inquiry and taken a plausible view, and whether the Pr. CIT's order was based on a proper examination of facts or a mere direction for a roving inquiry.

Which sections of the Income-tax Act were involved?

Section 263,Section 143(3),Section 144B,Section 68,Section 37(1),Section 142(1)

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, RAIPUR BENCH, “DB” RAIPUR

Before: SHRI R.K PANDA & SHRI PARTHA SARATHI CHAUDHURY

For Appellant: Shri Sunil Kumar Agrawal &, Ms. Vidya Verma, CAs
For Respondent: Shri Rituparna Namdeo, CIT-DR
Hearing: 04.08.2026Pronounced: 06.08.2026

PER PARTHA SARATHI CHAUDHURY, JM:

The present appeal preferred by the assessee emanates from the order of the Ld. Pr.CIT, Raipur-1 dated 19.03.2026 for the assessment year 2022-23 as per the grounds of appeal on record.

2.

The assessee is aggrieved with passing of order u/s. 263 of the Income Tax Act, 1961 (for short ‘the Act’) by the Ld. Pr. CIT through assumption of revisionary juri iction holding the assessment order to be erroneous so far it was preju

The order continues below.

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