BANNARIAMMAN EDUCATIONAL TRUST,COIMBATORE vs. PCIT, CENTRAL CIRCLE-3(2), CHENNAI

ITA 1378/CHNY/2025Status: DisposedITAT Chennai26 November 2025AY 2015-16Bench: 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's assumption of jurisdiction under Section 263 was invalid because the reassessment under Section 153C was for unabated years and based on material from a third party, not directly incriminating the assessee for those specific years. The PCIT should have targeted the original assessment orders, which were time-barred.

What were the facts?

The assessee trust's assessment was completed, and later reassessed under Section 153C based on material found during a search at a third party's premises. The PCIT initiated revision proceedings under Section 263, questioning the exemption granted on certain 'other income'.

What were the issues?

Whether the PCIT validly exercised revisional powers under Section 263 when the reassessment under Section 153C was for unabated years and the original assessment orders were time-barred for revision.

Which sections of the Income-tax Act were involved?

Section 153C,Section 263,Section 11(4A),Section 132,Section 143(3)

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Income Tax Appellate Tribunal, ‘A’ BENCH: CHENNAI

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

Hearing: 11.09.2025Pronounced: 26.11.2025

PER ABY T. VARKEY, JM: These are appeals preferred by the assessee against the order of the Learned Principal Commissioner of Income Tax (Central), (hereinafter

referred to as “the Ld.PCIT”), Chennai-1, dated 28.03.2025 for the Assessment Year (hereinafter referred to as "AY”) 2015-16 and order

dated 26.03.2025 for AY 2016-17 exercising his revisional power u/s.263

of the Income Tax Act, 1961 (hereinafter referred to as "t

The order continues below.

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