BADRI SINGH SISODIYA,INDORE vs. PCIT, INDORE

ITA 394/IND/2024Status: DisposedITAT Indore16 January 2026AY 2014-151 pages
AI SummaryDismissed

What did the Tribunal hold?

The tribunal noted that the assessee initially prayed for quashing of the revision orders but later modified the prayer to setting aside and remanding the matters for fresh adjudication. The Revenue objected to the remand, arguing that the assessee remained non-participative in the proceedings. The tribunal found merit in the Revenue's submissions and rejected the assessee's request for remand.

What were the facts?

Three appeals were filed by the assessee against revision orders passed by the Principal Commissioner of Income Tax (PCIT) under Section 263 of the Income-tax Act. These revision orders arose from ex-parte assessment orders passed by the National Faceless Assessment Centre. The assessee contended that the show-cause notices for the revision proceedings were sent to a wrong email address.

What were the issues?

Whether the revision orders passed by the PCIT under Section 263 were erroneous and prejudicial to the interest of revenue, considering the alleged incorrect service of notices and the assessee's non-participation. Whether the appeals should be remanded for fresh adjudication.

Which sections of the Income-tax Act were involved?

Section 263,Section 147,Section 144,Section 144B

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, INDORE BENCH, INDORE

Before: SHRI B.M. BIYANI & SHRI PARESH M. JOSHI

For Appellant: Shri Pankaj Shah & Soumya Bumb, ARs
For Respondent: Shri Anup Singh, CIT-DR (virtually)
Hearing: 13.01.2026Pronounced: 16.01.2026

Per B.M. Biyani, A.M.:

The captioned three (3) appeals are filed by same assessee against three separate revision-orders, all dated 21.02.2024 and all passed by learned PCIT, Indore-1 [“PCIT”] u/s 263 of Income-tax Act, 1961 [“the Act”] for Assessment-Years [“AYs”] 2013-14, 2014-15 and 2017-18, which in turn arise out of respective assessment-orders passed by National Faceless Assessment Centre, Delhi u/s 147 r.w.s. 144 & 144B of the Act.

Badri Singh Sisodiya ITA No. 393 to 395/Ind/2024 AYs:2013-14, 2014-15 & 2017-18

2.

Since these appeals relate to same assessee and the grounds as well

The order continues below.

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