SHARADA ELECTORS PRIVATE LIMITED,PUNE vs. PCIT, PUNE-3, PUNE

ITA 1432/PUN/2025Status: DisposedITAT Pune22 September 2025AY 2020-21Bench: <p>IN THE INCOME TAX APPELLATE TRIBUNAL</p> <p>PUNE BENCHES “B”, PUNE</p> <p>BEFORE DR.MANISH BORAD, ACCOUNTANT MEMBER</p> <p>AND SHRI VINAY BHAMORE, JUDICIAL MEMBER</p> <p>आयकर अपील सं. / ITA No.1432/PUN/2025</p> <p>Assessment Year : 2020-21</p> <p>Sharada Erectors Private Limited, Vs. PCIT, Pune-3</p> <p>11/1, Sharada Centre,</p> <p>Karve Road, Pune 411 004</p> <p>Maharashtra</p> <p>PAN : AACCS6028D</p> <p>Appellant Respondent</p> <p>Appellant by : Shri Kishor B. Phadke</p> <p>Respondent 20 pages
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What did the Tribunal hold?

The Tribunal held that some issues were not properly examined by the AO, warranting restoration to the AO for fresh examination. However, for other issues, the AO's findings were upheld, reversing the PCIT's view.

What were the facts?

The assessee company declared a loss for AY 2020-21. The Assessing Officer (AO) accepted the returned loss after scrutiny. The Principal Commissioner of Income Tax (PCIT) initiated proceedings under Section 263, deeming the assessment order erroneous and prejudicial to the revenue.

What were the issues?

Whether the assessment order was erroneous and prejudicial to the revenue due to inadequate examination by the AO on various disallowances and additions, and whether the PCIT correctly invoked Section 263.

Which sections of the Income-tax Act were involved?

Section 263,Section 14A,Section 43B,Section 36(1)(ii),Section 40(a)(ia),Section 201(1),Section 133(6),Section 69B,Section 115BBE

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

Before: DR.MANISH BORAD & SHRI VINAY BHAMORE

For Appellant: Shri Kishor B. Phadke
For Respondent: Shri Amit Bobde
Hearing: 27.07.2025Pronounced: 22.09.2025

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 30.03.2025 of Ld.PCIT, Pune-2 passed u/s.263 of the Income- tax Act, 1961 (hereinafter also called ‘the Act’).

2.

Brief facts of the case are that the assessee is a Private Limited Company engaged in the business of Construction. The assessee has constructed certain premises which are leased out to different occupants and earned rental income. The assessee has installed 9 wind Turbine Generators and the Electricity generated from the said Wind Turbine Generators are sold to either the State Electricity Distribution undertaking or to

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