MEGNANAPURAM PACCS,TIRUCHENDUR vs. PCIT,, MADURAI

ITA 895/CHNY/2025Status: DisposedITAT Chennai19 September 2025AY 2018-1927 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that the reassessment proceedings were initiated without proper sanction from the competent authority as prescribed under Section 151 of the Act. Consequently, the reassessment order was considered invalid, and the PCIT's revisionary order was also set aside.

What were the facts?

The assessee, a cooperative society, failed to file its income tax return for AY 2018-19. The Assessing Officer (AO) initiated reassessment proceedings based on information suggesting escaped income. The Principal Commissioner of Income Tax (PCIT) later revised the AO's reassessment order, deeming it erroneous and prejudicial to the revenue.

What were the issues?

The primary issue was the validity of the reassessment proceedings initiated due to improper sanction under Section 151. Another issue was whether the PCIT could revise an order that was itself passed without jurisdiction.

Which sections of the Income-tax Act were involved?

Section 147,Section 148,Section 148A,Section 151,Section 263,Section 80P,Section 139

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, B BENCH, CHENNAI

Before: SHRI MANU KUMAR GIRI & SHRI S.R.RAGHUNATHA

Hearing: 24.06.2025Pronounced: 19.09.2025

PER S. R. RAGHUNATHA, AM : This appeal by the assessee is filed against the order of the Commissioner of Income Tax (Appeals), PCIT, Madurai - 1, for the assessment year 2018-19, vide order dated 17.03.2025. 2. The grounds raised by the assessee are as follows: :-2-: ITA. No:895/Chny/2025 1) The revisional order of the PCIT, Madurai – 1 dated 17.03.2025 vide DIN & Order No. ITBA/REV/F/REV5/2024-25/10

The order continues below.

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