M/S. RMZ INFINITY (CHENNAI) PVT. LTD.,KANCHIPURAM vs. PCIT-4, , CHENNAI

ITA 511/CHNY/2025Status: DisposedITAT Chennai11 June 2025AY 2009-10Bench: SHRI ABY T VARKEY (Judicial Member), SHRI AMITABH SHUKLA (Accountant Member)1 pages
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What did the Tribunal hold?

The Tribunal held that Section 154 does not permit detailed inquiries or verification, and therefore, the AO cannot be faulted for not conducting them. Consequently, the PCIT's assumption of jurisdiction under Section 263 was incorrect, and the directions issued by the PCIT were inoperable.

What were the facts?

The assessee filed a rectification petition under Section 154 to correct errors in the assessment order, including capital gains calculation and income classification. The Assessing Officer (AO) passed an order rectifying these mistakes. The Principal Commissioner of Income Tax (PCIT) invoked Section 263, considering the AO's order erroneous and prejudicial to revenue as it was passed without detailed inquiry.

What were the issues?

Whether the PCIT's invocation of revisionary jurisdiction under Section 263 was valid when the AO passed a rectification order under Section 154 without conducting detailed inquiries, which are not permissible under Section 154.

Which sections of the Income-tax Act were involved?

Section 263,Section 154

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Cases cited in this judgment(3)Show list

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Income Tax Appellate Tribunal, ‘A’ BENCH: CHENNAI

Before: SHRI ABY T VARKEY & SHRI AMITABH SHUKLA

Hearing: 15.05.2025Pronounced: 11.06.2025

PER AMITABH SHUKLA, A.M :

This appeal is filed by the assessee against the order bearing DIN & Order No.ITBA/REV/F/REV5/2024-25/1070000889(1) dated 28.10.2024 of the Leaned Principal Commissioner of Income Tax,(herein after “PCIT’), Chennai u/s 263 for the assessment year 2009-10. 2.0 The only issue contested by the appellant assessee through its six grounds of appeal, is regarding t

The order continues below.

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