ALICON CASTALLOY LTD,PUNE vs. PCIT,-1, PUNE, PUNE

ITA 1377/PUN/2025Status: DisposedITAT Pune14 November 2025AY 2020-21Bench: MS.ASTHA CHANDRA, JUDICIAL MEMBER AND DR.DIPAK P. RIPOTE (Accountant Member)1 pages
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What did the Tribunal hold?

The Tribunal held that the Assessing Officer (AO) had conducted due verification regarding the trade creditors and arrived at a plausible view. Therefore, the Pr.CIT was precluded from invoking jurisdiction under Section 263 when two views were possible and the AO had adopted one. The assessment order was not erroneous or prejudicial to the revenue.

What were the facts?

The assessee filed an appeal against the order of the Principal Commissioner of Income Tax (Pr.CIT) under Section 263 of the Income Tax Act, 1961. The Pr.CIT had set aside the assessment order passed under Section 143(3) on the grounds that it was erroneous and prejudicial to the interest of the revenue, specifically concerning the issue of trade creditors.

What were the issues?

Whether the Pr.CIT was justified in invoking Section 263 of the Income Tax Act when the Assessing Officer had already conducted due inquiry and arrived at a plausible conclusion regarding trade creditors, especially when two views were possible.

Which sections of the Income-tax Act were involved?

Section 263,Section 143(3),Section 144B,Section 41(1),Section 142(1),Section 14A

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Income Tax Appellate Tribunal, PUNE BENCHES “A” :: PUNE

Before: MS.ASTHA CHANDRA & DR.DIPAK P. RIPOTE

For Appellant: Shri Nikhil S Pathak
For Respondent: Shri Aditya Shukla – CIT(DR)
Hearing: 17/09/2025Pronounced: 14/11/2025

PER DR. DIPAK P. RIPOTE, AM: This is an appeal filed by the assessee against the order of ld.Principal Commissioner of Income Tax, Pune-1, under section 263 of the Income Tax Act, 1961 dated 27.03.2025 for Assessment Year 2020-21 emanating from the Assessment Order u/s.143(3) of the Act, dated 20.09.2022. The Assessee has raised the following grounds of appeal : “1] The learned Pr.C1T erred in revising the asst, order passed u/s ITA No.1377/PUN/2025 [A] 143(3) r.w.s. 144B on the ground that it was erroneous and prejudicial to the interest of the revenue. 2] The Pr. C1T erred in revising the asst

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