M/S. VELJI ANANDJI,BHUJ-KUTCH vs. THE PR. CIT-1, RAJKOT, RAJKOT

ITA 111/RJT/2023Status: DisposedITAT Rajkot31 August 2026AY 2017-1810 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that the AO had conducted sufficient inquiry, distinguishing between 'lack of inquiry' and 'inadequate inquiry'. The PCIT cannot invoke Section 263 merely because he has a different opinion or believes further inquiry was needed.

What were the facts?

The assessee filed a return of income declaring Nil income. The assessment was completed accepting the returned income. The Principal Commissioner of Income-tax (PCIT) initiated revision proceedings under Section 263, alleging the Assessing Officer (AO) failed to make adequate inquiry regarding unsecured loans.

What were the issues?

Whether the PCIT correctly invoked revisional jurisdiction under Section 263 when the AO had conducted some inquiry, even if considered inadequate by the PCIT.

Which sections of the Income-tax Act were involved?

Section 263,Section 143(3),Section 142(1),Section 68

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, Rajkot Bench, Rajkot

Before: Dr. Arjun Lal Saini & Shri Sonjoy Sarma

Hearing: 09/07/2026Pronounced: 31/08/2026

Per, Dr. Arjun Lal Saini, AM:

By way of this appeal, the assessee has challenged the correctness of the order dated 03.02.2022 passed by the Learned Principal Commissioner of Income-tax (in short “Ld PCIT”) under section 263 of the Income-tax Act, 1961 (hereinafter referred to as 'the Act'), for the assessment year 2017-18. Grievances raised by the assessee, which, being interconnected, will be taken up together,

The order continues below.

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