DR. PRATAP PANDHIRANATH PATIL,PUNE vs. PCIT - 2, PUNE

ITA 1026/PUN/2025Status: DisposedITAT Pune23 September 2025AY 2020-21Bench: DR.MANISH BORAD (Accountant Member), SHRI VINAY BHAMORE (Judicial Member)6 pages
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What did the Tribunal hold?

The Tribunal held that the AO had conducted adequate inquiry and taken a permissible view. The PCIT's order was not justified as the AO's order was neither erroneous nor prejudicial to the revenue.

What were the facts?

The assessee claimed agricultural income, but the Assessing Officer (AO) made additions for unexplained agricultural receipts and disallowed expenses, treating them as 'Income from Other Sources'. The Principal Commissioner of Income-tax (PCIT) initiated revision proceedings under Section 263, believing the AO should have invoked Sections 68 and 69C.

What were the issues?

Whether the PCIT was justified in invoking Section 263 when the AO had conducted sufficient inquiry and taken a plausible view regarding agricultural income and expenses.

Which sections of the Income-tax Act were involved?

Section 263,Section 143(3),Section 144B,Section 68,Section 69C,Section 115BBE

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Income Tax Appellate Tribunal, PUNE BENCHES “B”, PUNE

Before: DR.MANISH BORAD & SHRI VINAY BHAMORE

For Appellant: Shri A.V.Iyer and Shri Siddhant G. Biswas
For Respondent: Shri Amit Bobde
Hearing: 19.08.2025Pronounced: 23.09.2025

PER DR. MANISH BORAD, ACCOUNTANT MEMBER :

The captioned appeal at the instance of assessee pertaining to A.Y. 2020-21 is directed against the order dated 05.02.2025 of PCIT, Pune-2 passed u/s.263 of the Income-tax Act, 1961 (hereinafter also called ‘the Act’) arising out of Assessment Order dated 12.09.2022 passed u/s.143(3) r.w.s144B of the Act.

2.

Registry has informed that there is delay of 23 days in preferring the instant appeal before this Tribunal. Assessee has filed an application for condonation of delay explaining the reasons which led to delay in filing of the appeal. The contents of the said application reads

The order continues below.

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