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

ITA 1478/CHNY/2025Status: DisposedITAT Chennai09 September 2025AY 2020-21Bench: SHRI S.S. VISWANETHRA RAVI (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 the issues were decided in the assessee's favor in its own case by a coordinate bench. The PCIT's order was found to be not tenable in law.

What were the facts?

The assessee, a banking company, filed its return of income. The Principal Commissioner of Income Tax (PCIT) invoked Section 263, holding the Assessing Officer's (AO) order to be erroneous and prejudicial to revenue. The PCIT set aside the assessment order for fresh assessment.

What were the issues?

Whether the PCIT correctly invoked Section 263 when the AO had made inquiries and adopted a possible view, especially when similar issues were decided in the assessee's favor by a coordinate bench.

Which sections of the Income-tax Act were involved?

Section 263,Section 143(3),Section 144B,Section 36(1)(vii),Section 36(1)(viia)

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Income Tax Appellate Tribunal, ‘A’ BENCH, CHENNAI

Before: SHRI S.S. VISWANETHRA RAVI & SHRI S.R. RAGHUNATHA

Hearing: 28.08.2025Pronounced: 09.09.2025

PER S.R.RAGHUNATHA, AM :

The captioned appeals are filed by the assessee against the order of the learned Principal Commissioner of Income Tax, Madurai – 1, [In short “the Ld.PCIT”] for the A.Ys. 2020-21 & 2021-22 respectively. Since the issues involved in both the appeals are identical, they are disposed of by a common order.

2.

The grounds raised by the assessee for A.Y. 2020-21 are as follow

The order continues below.

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