M/S. CITY UNION BANK LTD.,,KUMBAKONAM vs. PCIT,, MADURAI

ITA 1126/CHNY/2024Status: DisposedITAT Chennai18 December 2025AY 2018-19Bench: SHRI ABY T VARKEY (Judicial Member), SHRI S. R. RAGHUNATHA (Accountant Member)1 pages
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What did the Tribunal hold?

The Tribunal held that the PCIT erred in invoking Section 263 as the AO had made necessary inquiries and adopted a plausible view. Furthermore, the issues in question had been decided in favor of the assessee in its own case by a coordinate bench of the Tribunal.

What were the facts?

The assessee bank claimed deductions under various sections of the Income Tax Act. The Principal Commissioner of Income Tax (PCIT) invoked Section 263, holding the Assessing Officer's (AO) order to be erroneous and prejudicial to revenue due to insufficient inquiry. The assessee argued that the AO had made necessary inquiries and that the issues were decided in their favor in previous assessments.

What were the issues?

Whether the PCIT correctly invoked Section 263 when the AO had conducted inquiries and adopted a plausible view, especially when similar issues were decided in the assessee's favor in its own case.

Which sections of the Income-tax Act were involved?

Section 263,Section 36(1)(vii),Section 36(1)(viia)

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Income Tax Appellate Tribunal, ‘C’ BENCH, CHENNAI

Before: SHRI ABY T VARKEY & SHRI S. R. RAGHUNATHA

For Respondent: Shri. Bipin C.N., CIT
Hearing: 27.11.2025Pronounced: 18.12.2025

PER S. R. RAGHUNATHA, AM :

The captioned appeal is filed by the assessee against the order u/s.263 of the Income Tax Act, 1961 passed by the learned Principal Commissioner of Income Tax, Madurai – 1, [In short “the Ld.PCIT”] for the A.Y. 2018-19. 2. The grounds raised by the assessee for A.Y. 2018-19 are as follows:

1.

The order of the Learned Principal Commissioner of Income Tax, Madurai is against the law & contrary to the facts & circumstances that are p

The order continues below.

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