ICICI SECURITIES LIMITED,MUMBAI vs. PRINCIPAL COMMISSIONER OF INCOME TAX, MUMBAI -4, MUMBAI

ITA 3766/MUM/2025Status: DisposedITAT Mumbai06 January 2026AY 2020-21Bench: SHRI AMIT SHUKLA (Judicial Member), SMT RENU JAUHRI (Accountant Member)24 pages
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What did the Tribunal hold?

The Tribunal held that the Assessing Officer had conducted necessary inquiries and taken plausible views supported by law. The Principal Commissioner's assumption of jurisdiction under section 263 was found unsustainable as no error of law or fact prejudicial to the revenue was demonstrated.

What were the facts?

The assessee challenged a revisionary order under section 263 of the Income Tax Act. The Principal Commissioner had set aside the assessment order, alleging the Assessing Officer failed to make adequate inquiries on various deductions claimed by the assessee.

What were the issues?

Whether the Principal Commissioner correctly invoked section 263 by alleging inadequate inquiries by the Assessing Officer, and if the deductions claimed by the assessee were indeed erroneous and prejudicial to the revenue.

Which sections of the Income-tax Act were involved?

Section 263,Section 37(1),Section 36(1)(iii),Section 80G

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Income Tax Appellate Tribunal, ‘C’ BENCH

Before: SHRI AMIT SHUKLA & SMT RENU JAUHRI

For Appellant: Shri Riken Shah
For Respondent: Ms. Kavita Kaushik (Sr.DR)
Hearing: 21/11/2025Pronounced: 06/01/2026

PER AMIT SHUKLA (J.M): The present appeal has been preferred by the assessee against the order dated 28.03.2025 passed by the learned Principal Commissioner of Income Tax, Mumbai–4, in exercise of revisionary juri iction under section 263 of the Income- tax Act, 1961, for the assessment year 2020–21. 2. Through the grounds of appeal, the assessee has, inter alia, challenged:

2 ICICI Securities Limited (i) the very assumption of juri iction under section 263 of the Act as being bad in law; (ii) the revision in respect of deduction allowed for club membership expenses amounting to ₹40,23,516/- under section 37(1); (iii) the revision relating to deduction allowed for Employee Stock Option Plan (“ESOP”) expenditure amo

The order continues below.

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