KPA APPARELS PRIVATE LIMITED,DELHI vs. INCOME TAX OFFICER WARD 14(3), DELHI

ITA 2798/DEL/2025Status: DisposedITAT Delhi14 May 2026AY 2020-2122 pages
AI SummaryAllowed

What were the facts?

The assessee's assessment order was revised by the Principal Commissioner of Income Tax (PCIT) under Section 263, citing alleged violations of Section 269SS and 269T of the Income Tax Act based on audit objections. The PCIT believed the assessment order was passed without proper inquiry and was prejudicial to the revenue.

What did the Tribunal hold?

The Tribunal held that the Assessing Officer (AO) had conducted proper inquiries and verification during the assessment proceedings. Therefore, the assessment order was neither erroneous nor prejudicial to the interest of the Revenue.

What were the issues?

Whether the PCIT correctly invoked Section 263 powers to revise an assessment order passed after due inquiry by the AO, and whether the assessment order was erroneous and prejudicial to the revenue.

Which sections of the Income-tax Act were involved?

Section 263,Section 143(3),Section 269SS,Section 271D,Section 269T,Section 271E,Section 73,Section 185

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, DELHI BENCH ‘B’: NEW DELHI

For Appellant: Shri S. Sadhoo, CA &, Shri. J.M. Singh, CAs
For Respondent: Ms. Pooja Swaroop, CIT- DR
Hearing: 18/02/2026Pronounced: 14/05/2026

PER MANISH AGARWAL, AM: This appeal is filed by the Assessee against the order of the Ld. Principal Commissioner of Income Tax, Delhi-4 [ld. PCIT, in short] dated 17.03.2025 in Revision No. PCIT, Delhi-4/Revision-263/100000777938/2025 passed u/s 263 of the Income Tax Act, 1961 (hereinafter referred as ‘the Act’) revising the Assessment Order passed u/s 143(3) of the Act dated 17.09.2022 for AY 2020-

21.2.

The assessee has raised the following grounds of appeal:

“1. That on the facts and circumstances of the case and in law, the order dated 17.03.2025, passed by the Principal Commissioner of Income Tax, Delhi-4 ['Ld. PCIT'], under section 263 of the Income Tax Act, 1961 ('the Act') setting aside the assessment to be

The order continues below.

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