BHAVIN MUKESH CHANDARANA ,RAJKOT vs. THE PRINCIPAL COMMISSIONER OF INCOME TAX-1, RAJKOT

ITA 411/RJT/2026Status: DisposedITAT Rajkot31 August 2026AY 2022-235 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that the Assessing Officer had already examined the issue during the original assessment, considering the assessee's denial and confirmation from the developer. The PCIT's revision was based on a change of opinion without new material, thus not satisfying the conditions for Section 263.

What were the facts?

The PCIT invoked Section 263 to revise an assessment order, citing an alleged cash payment of ₹14,95,000 for a property purchase based on seized data. The assessee denied the transaction, and the developer also confirmed no such transaction occurred.

What were the issues?

Whether the PCIT's revisionary power under Section 263 was validly exercised when the Assessing Officer had already examined the issue and the assessee provided a plausible explanation supported by documentary evidence.

Which sections of the Income-tax Act were involved?

Section 263,Section 143(3),Section 144B,Section 69

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, Rajkot Bench, Rajkot

Before: Dr. Arjun Lal Saini & Shri Sonjoy Sarma

For Appellant: Shri R. D. Lalchandani, Ld. AR
For Respondent: Shri Gopi Nath Chaubey, Ld. Sr. DR
Hearing: 23/06/2026Pronounced: 31/08/2026

Per, Shri Sonjoy Sarma, JM: The assessee is in appeal before this Tribunal against the order passed by the Principle Commissioner of Income Tax [hereinafter referred to as “PCIT”], Rajkot- 1, dated 24.02.2026, whereby the Ld. PCIT, Rajkot-1 directed the Assessing Officer to set aside the assessment order dated 19.03.2024 passed under section 143(3) read with section 144B of the Income-tax Act, 1961, with a direction to examine the issue relating to the alleged cas

The order continues below.

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