COURSE5 INTELLIGENCE LIMITED ,BANGALORE vs. PR. COMMISSIONER OF INCOME TAX, BENGALURU-2, BENGALURU

ITA 1288/BANG/2025Status: DisposedITAT Bangalore28 November 2025AY 2020-21Bench: SHRI. LAXMI PRASAD SAHU (Accountant Member), SHRI. SOUNDARARAJAN K (Judicial Member)5 pages
AI SummaryDismissed

What did the Tribunal hold?

The Tribunal upheld the order of the Pr.CIT, agreeing that the disallowance of employee's contribution to PF/ESI was justified as per Supreme Court judgment. The Tribunal also directed verification of TDS deduction on professional services and rent payments.

What were the facts?

The assessee filed its return of income, which was selected for scrutiny. The AO disallowed Rs.6,59,463/- towards education cess. The Pr.CIT exercised his revisional jurisdiction under Section 263, finding the assessment order erroneous and prejudicial to the revenue's interest, particularly concerning TDS on professional services and rent, and unremitted employee contributions to PF/ESI.

What were the issues?

Whether the Pr.CIT correctly exercised his revisional powers under Section 263? Whether TDS was correctly deducted on professional services and rent payments? Whether employee contributions to PF/ESI were correctly disallowed.

Which sections of the Income-tax Act were involved?

Section 263,Section 143(3),Section 36(1)(va),Section 10AA

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, “A” BENCH : BANGALORE

Before: SHRI. LAXMI PRASAD SAHU & SHRI. SOUNDARARAJAN K

For Appellant: Smt. Suman Lunkar, CA
For Respondent: Shri. Balusamy N, JCIT(DR)(ITAT), Bangalore
Hearing: 12.11.2025Pronounced: 27.11.2025

Per Laxmi Prasad Sahu, Accountant Member :

This is an appeal filed by the assessee against the Order passed by the learned PCIT, vide DIN ITBA/REV/F/REV5/2024-25/1075159137(1) dated 28.03.2025. 2. Briefly stated facts of the case are that assessee filed return of income on 12.02.2021 declaring total income of Rs.6,16,32,020/-. The case was selected for scrutiny and statutory notices were issued to the assessee. During the course of assessment proceedings, assessee filed detailed written submissions. After considering the written submissions the AO disallowed Rs.6,59,463/- towards education cess and income was assessed

The order continues below.

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