CISCO COMMERCE INDIA PRIVATE LIMITED,BANGALORE vs. PRINCIPAL COMMISSIONER OF INCOME TAX, PCIT, BENGALURU-2, BANGALORE

ITA 1235/BANG/2025Status: DisposedITAT Bangalore05 March 2026AY 2021-22Bench: SHRI PRASHANT MAHARISHI (Vice President), SHRI SOUNDARARAJAN K. (Judicial Member)1 pages
AI SummaryDismissed

What did the Tribunal hold?

The Tribunal upheld the PCIT's order, finding that the AO had failed to conduct necessary inquiries regarding the provision, quantification, and use of refund liabilities. This lack of inquiry rendered the assessment order erroneous and prejudicial to the interests of revenue.

What were the facts?

The Principal Commissioner of Income-tax (PCIT) initiated revision proceedings under Section 263, stating the Assessing Officer's (AO) assessment order was erroneous and prejudicial to revenue due to insufficient examination of 'refund liabilities'. The assessee contended that the AO conducted due inquiry and the assessment order was not erroneous.

What were the issues?

Whether the PCIT was justified in revising the assessment order under Section 263 due to the AO's alleged lack of inquiry into refund liabilities. Whether the assessment order was erroneous and prejudicial to the interests of revenue.

Which sections of the Income-tax Act were involved?

Section 263,Section 143(3),Section 144B

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Income Tax Appellate Tribunal, “A” BENCH: BANGALORE

Before: SHRI PRASHANT MAHARISHI & SHRI SOUNDARARAJAN K.

For Appellant: Shri Nageshwar Rao, Advocate
For Respondent: Smt. N. Hemalatha, CIT(DR)(ITAT), Bengaluru
Hearing: 28.01.2026Pronounced: 05.03.2026

Per Prashant Maharishi, Vice President

1.

Cisco Commerce India Pvt. Ltd. has filed an appeal for the assessment year 2021-22 against the order passed under Section 263 of the Income Tax Act, 1961 by the Principal Commissioner of Income-tax, Bengaluru-2, dated 29.3.2025. The PCIT found that the assessment order passed under Section 143(3) read with 144B was erroneous and prejudicial to Revenue because the issue of 'refund liabilities' was not properly examined by the Assessing Officer.

2.

The assessee is dissatisfied with the revisionary order and has contested it on the grounds that the order issued

The order continues below.

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