RASHI PERIPHERALS LIMITED,MUMBAI vs. PCIT, MUMBAI-3, MUMBAI

ITA 3671/MUM/2025Status: DisposedITAT Mumbai06 January 2026AY 2022-23Bench: SHRI PAWAN SINGH (Judicial Member), SHRI OMKARESHWAR CHIDARA (Accountant Member)1 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that while the AO's order was erroneous due to non-application of mind regarding the delay in filing Form 10DA, it did not prejudice the revenue as the AO had conducted inquiries and allowed the claim on merits. Therefore, the PCIT's order under Section 263 was not valid.

What were the facts?

The assessee claimed a deduction under Section 80JJAA, but the Form 10DA was filed 23 days late. The Assessing Officer (AO) allowed the deduction after scrutiny, but the Principal Commissioner (PCIT) revised the order under Section 263, directing disallowance.

What were the issues?

Whether a procedural delay in filing Form 10DA, even if condoned by a higher authority, renders an assessment order erroneous and prejudicial to the revenue, justifying revision under Section 263.

Which sections of the Income-tax Act were involved?

Section 80JJAA,Section 263,Section 143(1),Section 143(3)

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ITA No. 3671/Mum/2025 Rashi Peripherals Limited IN THE INCOME TAX APPELLATE TRIBUNAL "D" BENCH, MUMBAI BEFORE SHRI PAWAN SINGH, JUDICIAL MEMBER& SHRI OMKARESHWAR CHIDARA, ACCOUNTANT MEMBER Rashi Peripherals Limited, (Physical hearing) 5th Floor, Aristo House, Corner of Telligully Circle, Andheri (East), Mumbai - 400069. [PAN: AAACR2162H] Appellant / Assessee Assessee by Revenue by Date of Institution Date of hearing Date of pronouncement DPCIT, Mumbai - 3 Vs Room No. 612, 6th Floor, Aayakar Bhavan, Maharshi Karve Road, Mumbai - 400020. Respondent / Revenue Shri Lalchand Choudhary, FCA Shri Umashankar Prasad, CIT -DR/ Shri Annavaran Kosuri Sr DR 23.05.2025 07.11.2025 07.11.2025/06.01.2026 Order under section 254(1) of Income Tax Act PER PAWAN SINGH, JUDICIAL MEMBER;

1.

This appeal by assessee is directed against the order of Id. Pr. CIT - 3, Mumbai dated 26.03.2025 for A.Y. 2022-23.The assessee has raised following grounds of appeal:

"

1.

The appellant prefers the following Appeal against the order dated 26/03/2025 of the Principal Commissioner of Income Tax, Mumbai-3 (hereinafter referred to as "The PCIT") passed under section 263 of the Income Ta

The order continues below.

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