HSBC SECURITIES AND CAPITAL MARKETS (INDIA) PRIVATE LIMITED,MUMBAI vs. PRINCIPAL COMMISSIONER OF INCOME-TAX, MUMBAI-4, MUMBAI

ITA 2586/MUM/2024Status: DisposedITAT Mumbai10 February 2025AY 2014-15Bench: SHRI NARENDER KUMAR CHOUDHRY (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)20 pages
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What did the Tribunal hold?

The Tribunal held that the revisionary proceedings under section 263 were initiated beyond the period of limitation. The limitation for revisionary proceedings is to be reckoned from the date of the original assessment order when the issues involved are distinct from the reassessment proceedings.

What were the facts?

The assessee's original assessment order was passed on 17.01.2018. Subsequently, reassessment proceedings were initiated, and an order was passed on 30.03.2022. The PCIT initiated revisionary proceedings under section 263, issuing a notice on 25.09.2023.

What were the issues?

Whether the revisionary proceedings under section 263 were initiated within the prescribed limitation period, considering the original assessment and subsequent reassessment orders.

Which sections of the Income-tax Act were involved?

Section 263,Section 147,Section 143(3),Section 144C,Section 154,Section 144B,Section 14A

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Income Tax Appellate Tribunal, MUMBAI BENCH “E”, MUMBAI

Before: SHRI NARENDER KUMAR CHOUDHRY & SHRI GIRISH AGRAWAL

For Appellant: Ms. Krupa Gandhi, Ld. A.R, Shri Riken Shah, Ld. A.R
For Respondent: Shri Biswanath Das, Ld. D.R
Hearing: 31.01.2025Pronounced: 10.02.2025

Per : Narender Kumar Choudhry, Judicial Member:

This appeal has been preferred by the Assessee against the order dated 26.03.2024, impugned herein, passed by the Ld. Principal Commissioner of Income Tax (in short Ld. PCIT) under section 263 of the Income Tax Act, 1961 (in short ‘the Act’) for the A.Y. 2014-15. 2 M/s. HSBC Securities and Capital Markets (India) Private Limited

2.

In the instant case, the Assessee had declared its total income at Rs.28,06,90,350/- by filing its return of income on 28.11.2014, which was selecte

The order continues below.

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