UNITED INDIA INSUANCE CO LIMITED,CHENNAI vs. PCIT 3, CHENNAI

ITA 683/CHNY/2023Status: DisposedITAT Chennai05 January 2026AY 2017-1838 pages
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What did the Tribunal hold?

The Tribunal held that the PCIT's revision order regarding Section 10(38) was not justified as similar claims were allowed in earlier years and the assessee's position was legally tenable. The corrigendum was quashed as it was issued beyond the limitation period and introduced a new issue.

What were the facts?

The assessee claimed profit on sale of investments as exempt under Section 10(38). The Principal Commissioner of Income Tax (PCIT) invoked Section 263, holding the assessment order erroneous and prejudicial to revenue. A corrigendum was later issued to address prior period expenditure, which the assessee challenged.

What were the issues?

Whether the PCIT was justified in revising the assessment order under Section 263 concerning the exemption under Section 10(38) and whether the corrigendum issued was valid.

Which sections of the Income-tax Act were involved?

Section 10(38),Section 263,Section 143(3)

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Before: Shri S.S. Viswanethra Ravi & Shri Jagadish

For Appellant: Shri S. Sundararaman, CA, Ms. V. Pushpa, Sr. Standing Counsel
Hearing: 07.10.2025

PER S.S. VISWANETHRA RAVI, JUDICIAL MEMBER:

The appeal in ITA No. 1759/Chny/2019 filed by the assessee is directed against the order dated 29.03.2019 passed by the Id. Principal Commissioner of Income Tax-3, Chennai for the assessment year 2014- 1

The order continues below.

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