CISCO SYSTEMS (INDIA) PRIVATE LIMITED,BANGALORE vs. THE PRINCIPAL COMMISSIONER OF INCOME TAX - 2, KORAMANGALA, BANGALORE
What did the Tribunal hold?
The Tribunal held that the AO's assessment order was erroneous and prejudicial to the revenue due to a complete absence of inquiry on significant claims. The revisionary order passed by the PCIT under Section 263 was upheld.
What were the facts?
The assessee claimed deductions for post-employment benefit obligations and adjusted foreign exchange gains. The PCIT initiated revision proceedings under Section 263, alleging the Assessing Officer (AO) failed to conduct proper inquiries on these substantial claims.
What were the issues?
Whether the AO's assessment order was erroneous and prejudicial to the revenue due to lack of inquiry on claims related to post-employment benefits and foreign exchange gains.
Which sections of the Income-tax Act were involved?
Section 263,Section 143(3),Section 144B,Section 37(1),Section 43A,Section 36(1)(iv),Section 36(1)(v),Section 43B
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Cases cited in this judgment(4)Show listHide list
Detected automatically from the text. Citations are also linked where they appear in the judgment. The count shows how many other judgments on BharatTax rely on the same authority.
- Malabar Industrial Co. Ltd. v. CIT2,943 citing109 Taxmann 66 · 2000 · SC · Read judgment
- CIT v. Usha International Ltd.231 citing348 ITR 485 · 2012 · HC · Read judgment
- Torrent Pharmaceuticals Ltd. v. DCIT40 citing97 Taxmann.com 671 · 2018 · ITAT
- Cognizant Technology Solutions India (P.) Ltd. v. ACIT8 citing131 Taxmann.com 346 · 2021 · HC
Income Tax Appellate Tribunal, ‘A’ BENCH, BANGALORE
Before: SHRI WASEEM AHMED & SHRI SOUNDARARAJAN K
PER WASEEM AHMED, ACCOUNTANT MEMBER:
The present appeal has been instituted by the assessee against the order of the Ld. PCIT passed u/s 263 of the Act dated 29.03.2025
The assessee in the memo of appeal raised multiple grounds numbered 1 to 7, which we, for the sake of brevity and convenience are not inclined to reproduce here.
The grounds of appeal filed by the assessee are interconnected and pertains to revisionary order u/s 263 passed by the Ld. PCIT.
The brief facts of the case in hand are that the assessee filed its ROI for the subjected AY declaring an amount of Rs. 8,69,50,52,060/-. The case of assessee was s
The order continues below.
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More judgments on Section 263
- Gillette India Limited, Mumbai vs Principal Commissioner of Income Tax, JaipurITA 1316/JPR/2026[2018-19]Status: Disposed16 Oct 2026AY 2018-19
- Neo Structo Construction P. Ltd., Ahmedabad vs The Pr. CIT- 3, AhmedabadITA 1216/AHD/2026[2015-2016]Status: Disposed16 Oct 2026AY 2015-2016
- Vimal Harilal Baldania, Gandhidham vs The ITO Ward 2, GandhidhamITA 770/RJT/2025[2017-18]Status: Disposed15 Oct 2026AY 2017-18
- J.D. Marketing, Kolkata vs ITO, Ward 37(1), KolkataITA 1493/KOL/2026[2015-2016]Status: Disposed15 Oct 2026AY 2015-2016
- J.D. Marketing, Kolkata vs ITO, Ward 37(1), KolkataITA 1492/KOL/2026[2013-2014]Status: Disposed15 Oct 2026AY 2013-2014
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