RAKESH KUMAR GUPTA,LUDHIANA vs. PRINCIPAL COMMISSIOONER OF INCOME TAX-1, LUDHIANA, LUDHIANA

ITA 617/CHANDI/2026Status: DisposedITAT Chandigarh21 August 2026AY 2022-234 pages
AI SummaryAllowed

What were the facts?

The assessee, engaged in trading iron and steel scrap, booked purchases of Rs. 8,66,05,708/-. The Pr. CIT initiated revision proceedings alleging excess purchases of Rs. 49,59,861/- based on a backward calculation from Tax Collected at Source (TCS). The assessee provided a reconciliation of purchases and explained the differential.

What did the Tribunal hold?

The Tribunal held that the assessee had duly reconciled and explained the alleged differential in purchases. The Pr. CIT's revisionary order was based on a backward calculation without independent findings on the assessee's explanation, thus not fulfilling the conditions for revision.

What were the issues?

Whether the Pr. CIT's revisionary order under Section 263 was justified when the assessee had provided a satisfactory reconciliation of purchases and the Pr. CIT failed to render independent findings.

Which sections of the Income-tax Act were involved?

Section 263,Section 206C(1)

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, “B” BENCH, CHANDIGARH

Before: HON’BLE SHRI MANOJ KUMAR AGGARWAL, AM & HON’BLE SHRI RAJESH DAMODARLAL SHARMA, JM

RAJESH DAMODARLAL SHARMA (Judicial Member)

1.

Aforesaid appeal by the assessee is directed against the revisionary order passed u/s 263 by Ld. Principal Commissioner of Income Tax, Ludhiana – 1 (Pr. CIT) on 10.02.2026 proposing revision of an assessment order passed by the Ld. AO u/s 143(3) r.w.s. 144B of the Income Tax Act, 1961 on 11.03.2024 accepting returned income of Rs.17.57 L

The order continues below.

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