SRI EDUPAYALA VANA DURGA BHAVANI,HYDERABAD vs. INCOME TAX OFFICER, WARD-1, SANGAREDDY

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ITA 399/HYD/2025Status: DisposedITAT Hyderabad08 October 2025AY 2016-1720 pages
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What did the Tribunal hold?

The Tribunal agreed with the PCIT that the AO's order was erroneous for not properly examining the cash deposits and arbitrarily estimating income. However, the Tribunal modified the PCIT's direction to treat the entire deposits as unexplained, remanding the matter for fresh adjudication.

What were the facts?

The assessee, an AOP, failed to file its return of income. The AO initiated reassessment proceedings under Section 147 and estimated income at 8% of cash deposits after the assessee did not respond to notices. The PCIT invoked Section 263, finding the AO's order erroneous and prejudicial to revenue.

What were the issues?

Whether the PCIT correctly invoked Section 263 when the original assessment order was allegedly invalid, and whether the AO's estimation of income was erroneous and prejudicial to revenue.

Which sections of the Income-tax Act were involved?

Section 144,Section 147,Section 148,Section 142(1),Section 263,Section 69A,Section 115BBE,Section 10(23BBA)

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Income Tax Appellate Tribunal, Hyderabad ‘ A ‘ Bench, Hyderabad

आदेशकी �ितिलिप अ�ेिषत/ Copy of the order forwarded to:- 1. िनधा�रती/The : Sri Edupayala Vana Durga Bhavani, E- Block, Flat No.101, Aditya Empress Towers, Assessee Shaikpet Nala Tolichowk, Golconda Post, Hyderabad-500008. 2. राज�/ : The Income Tax Officer, Ward-1, The Sangareddy Revenue 3. The Principal Commissioner of Income Tax, Hyderabad. 4. िवभागीय�ितिनिध, आयकर अपीलीय अिधकरण, हैदराबाद / DR, ITAT, Hyderabad 5. गाड�फ़ाईल / Guard file

आदेशानुसार / BY ORDER

Sr. Private Secretary ITAT, Hyderabad

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