DABUR INDIA LTD.,NEW DELHI vs. PCIT - 1, NEW DELHI

ITA 2075/DEL/2024Status: DisposedITAT Delhi14 November 2025AY 2018-19Bench: SHRIS.RIFAUR RAHMAN (Accountant Member), SHRI VIMAL KUMAR (Judicial Member)23 pages
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What did the Tribunal hold?

The Tribunal held that the PCIT's order under Section 263 was not sustainable as it was based on mere inquiries and lacked specific findings about how the assessment order was prejudicial to the revenue's interest. The Tribunal found that the Assessing Officer had taken a possible view based on available material.

What were the facts?

The Principal Commissioner of Income-tax (PCIT) initiated proceedings under Section 263 of the Income Tax Act, 1961, against Dabur India Limited. The PCIT believed the assessment order was erroneous and prejudicial to the revenue's interest due to alleged inadequate verification of deductions claimed by the assessee.

What were the issues?

Whether the PCIT correctly invoked Section 263 to revise an assessment order when the Assessing Officer had made a possible assessment based on available documents and the PCIT's order lacked specific findings of prejudice to revenue?

Which sections of the Income-tax Act were involved?

Section 263,Section 35(2AB),Section 80IA,Section 80IC,Section 14A,Section 80JJAA,Section 35(1)

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Income Tax Appellate Tribunal, DELHI BENCHES ‘B’: NEW DELHI.

For Appellant: Shri M.P. Rastogi, Advocate
For Respondent: Shri Sanjeev Kaushal, CITDR
Hearing: 18.08.2025

PER S. RIFAUR RAHMAN, ACCOUNTANT MEMBER :

1.

The assessee has filed appeal against the order of the ld. Principal Commissioner of Income-tax, Delhi-1[“Ld. PCIT”, for short] dated 29.03.2024for the Assessment Year 2018-19. 2. Brief facts of the case are, the case of the assessee was picked up for scrutiny for AY 2018-19 and the assessment under section 143(3) of the Income-tax Act, 1961 (for short ‘the Act’) was completed on 29.10.2021. Ld. PCIT, Delhi–1 on verification of the abovesaid assessment record observed that the order passed by the AO is erroneous insofar as it is prejudicial to the interest of Revenue for the reasons that historically issues on which addition was made in earlier years but no such disallowance/addition was made in this year u/s

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