GMM PFAULDER LTD.,AHMEDABAD vs. THE PR.CIT, AHMEDABAD-1, AHMEDABAD

ITA 839/AHD/2025Status: DisposedITAT Ahmedabad28 October 2025AY 2020-21Bench: SHRI SIDDHARTHA NAUTIYAL (Judicial Member), SHRI NARENDRA PRASAD SINHA (Accountant Member)1 pages
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What did the Tribunal hold?

The Tribunal held that the Assessing Officer had conducted due inquiries and taken plausible views supported by judicial precedents on all three issues. Therefore, the Pr. CIT's assumption of jurisdiction under Section 263 was unjustified.

What were the facts?

The Principal Commissioner of Income Tax (Pr. CIT) initiated revision proceedings under Section 263 against the assessee's assessment order. The Pr. CIT believed the assessment order was erroneous and prejudicial to revenue regarding depreciation on goodwill, provision for warranty, and deduction under Section 80G for CSR expenditure.

What were the issues?

Whether the Pr. CIT was justified in invoking Section 263 to revise an assessment order where the Assessing Officer had made inquiries and taken a plausible view on depreciation on goodwill, provision for warranty, and Section 80G deduction for CSR expenditure.

Which sections of the Income-tax Act were involved?

Section 263,Section 32,Section 80G,Section 37(1),Section 135

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Income Tax Appellate Tribunal, “ D ” BENCH, AHMEDABAD

Before: SHRI SIDDHARTHA NAUTIYAL & SHRI NARENDRA PRASAD SINHA

For Appellant: Shri S.N. Soparkar, Sr. Advocate
Hearing: 09/09/2025

PER SIDDHARTHA NAUTIYAL, JM: This appeal filed by the assessee is directed against the order of Learned Principal Commissioner of Income-Tax, Ahmedabad-1 [hereinafter referred to as “Ld. Pr. CIT” for short] dated 07/03/2025 passed in exercise of his revisionary juri iction under Section 263 of the Income-Tax Act, 1961 [hereinafter referred to as "the Act" for short] for Assessment Year (AY) 2020-

21.2.

The assessee has raised the following grounds of appeal: GMM Pfaulder Ltd. vs. PCI

The order continues below.

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