VIIKING MEDIA AND ENTERTAINMENT PVT. LTD.,MUMBAI vs. DCIT- CENTRAL CIRCLE 2(2), MUMBAI

ITA 3430/MUM/2025Status: DisposedITAT Mumbai20 January 2026AY 2018-19Bench: SHRI SANDEEP GOSAIN (Judicial Member), SHRI OM PRAKASH KANT ( (Accountant Member)1 pages
AI SummaryDismissed

What did the Tribunal hold?

The Tribunal concurred with the PCIT, finding that the AO should have examined the seized material in light of the Supreme Court's ruling in Abhisar Buildwell P Ltd. The Tribunal held that the PCIT's revision was justified as the AO's omission made the assessment erroneous and prejudicial to the revenue.

What were the facts?

The assessee's assessment orders under Section 143(3) read with Section 153A were revised by the Principal Commissioner of Income Tax (PCIT) under Section 263. The PCIT believed the Assessing Officer (AO) erred by not disallowing the carry forward of losses due to a change in shareholding, invoking Section 79.

What were the issues?

Whether the PCIT correctly invoked revisionary powers under Section 263 when the AO failed to disallow carry forward of losses due to change in shareholding as per Section 79, and if the assessment was erroneous and prejudicial to revenue.

Which sections of the Income-tax Act were involved?

Section 263,Section 143(3),Section 153A,Section 79,Section 132(1)

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Income Tax Appellate Tribunal, MUMBAI BENCH “F” MUMBAI

Before: SHRI SANDEEP GOSAIN & SHRI OM PRAKASH KANT

For Appellant: Mr. Rajjev Khandelwal, Mr. Vivek Perampurna, CIT-DR
Hearing: 20/01/2026

PER BENCH

These appeals by the assessee are directed against separate revisionary orders passed by the Learned Principal Commissioner of Income Tax (hereinafter ‘Ld. PCIT’) under Section 263 of the Income Tax Act, 1961 (hereinafter ‘the Act’) for AY 2017-18 to 2021-22. The challenge primarily assails the juri iction of the Ld. PCIT in setting aside the assessment order(s) passed under Section 143(3) read with Section 153A, contending that the same was neither

Viiking Media and Entertainment Pvt. Ltd Viiking Media and Entertainment Pvt. Ltd erroneous nor prejudicial to the interests of

The order continues below.

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