NOKEN VITRIFIED PVT LTD,MORBI vs. THE PR. CIT-1, RAJKOT-1, RAJKOT

ITA 600/RJT/2026Status: DisposedITAT Rajkot31 August 2026AY 2019-206 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that the AO had conducted an inquiry and taken a possible view, which cannot be treated as erroneous simply because the PCIT held a different opinion. The conditions for invoking section 263 were not met.

What were the facts?

The assessee's assessment order was revised by the PCIT under section 263, who believed the Assessing Officer (AO) failed to adequately inquire into alleged cash deposits of Rs. 22,00,000/-. The AO had accepted the assessee's returned income after the assessee denied any transactions with the party involved.

What were the issues?

Whether the PCIT was justified in exercising revisionary jurisdiction under section 263 when the AO had conducted an inquiry and accepted the assessee's explanation.

Which sections of the Income-tax Act were involved?

Section 263,Section 147,Section 148,Section 144B,Section 131(1A),Section 69A,Section 115BBE

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 Mehul Ranpura, Ld. AR
For Respondent: Shri Ravinder Sindhu, Ld. CIT(DR)
Hearing: 25/08/2026Pronounced: 31/08/2026

Per, Shri Sonjoy Sarma, JM: This appeal is filed by the assessee against the order passed by the Ld.

Principal Commissioner of Income-tax, Rajkot-1 "PCIT"), under section 263 of the Income-tax Act, 1961 ["the Act"], dated 24.02.2026, whereby the Ld. PCIT revised the assessment order passed by the Assessing Officer under section 147 of the Act dated 11.10.2023 for Assessment Year 2019-20. 02. Brief facts of the case are that the assessee, is a private limi

The order continues below.

Read the full judgment

A free account opens 10 full judgments a month. Re-reading one you have already opened does not count again.

Create a free accountSign in

See plans and prices

The summary, the parties, the sections and the citations above are open to everyone and always will be. Only the text of the order and the PDF are metered.

More judgments on Section 263

All 13,616 judgments and leading authorities on Section 263 →

Recent GST High Court judgments

Search GST case law →