JAIN ENTERPRISES, BHILAI,DURG vs. PCIT, RAIPUR-1, RAIPUR

ITA 187/RPR/2025Status: DisposedITAT Raipur11 February 2026AY 2018-19Bench: SHRI PARTHA SARATHI CHAUDHURY (Judicial Member), SHRI AVDHESH KUMAR MISHRA (Accountant Member)21 pages
AI SummaryDismissed

What did the Tribunal hold?

The Tribunal held that the Assessing Officer had not properly inquired into the anomaly in stock, making the assessment order erroneous and prejudicial to the revenue. The Principal Commissioner rightly exercised his jurisdiction under Section 263.

What were the facts?

The assessee's reopened assessment order was revised under Section 263 of the Income Tax Act due to an anomaly in the closing stock of raw materials. The assessee attributed this anomaly to a change in the GST regime and errors in reporting, submitting a revised Annexure-I which was not filed before the Assessing Officer.

What were the issues?

Whether the Principal Commissioner correctly invoked Section 263 when the Assessing Officer failed to conduct adequate inquiries regarding stock discrepancies, leading to an order prejudicial to revenue.

Which sections of the Income-tax Act were involved?

Section 263,Section 147,Section 144B,Section 142(1),Section 148

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Income Tax Appellate Tribunal, RAIPUR BENCH, RAIPUR

Before: SHRI PARTHA SARATHI CHAUDHURY, JM & SHRI AVDHESH KUMAR MISHRA, AM

For Appellant: Shri S. R. Rao, Advocate
Hearing: 07/01/2026

Per Avdhesh Kumar Mishra, AM: This appeal for Assessment Year (‘AY’) 2018-19 filed by the assessee is directed against the order dated 24.03.2025 of the Principal Commissioner of Income Tax, Raipur-1 (‘PCIT’) passed under section 263 of the Income Tax Act, 1961 (‘Act’).

2.

Initial grounds of appeal raised by the assessee were substituted, vide letter dated 07.07.2025, with the following grounds:

“1. In the facts and

The order continues below.

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