MEASAGE.OSAKA ALLOYS AND STEEL (P) LTD,JALANDHAR vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-II, JALANDHAR

ITA 347/ASR/2019Status: DisposedITAT Amritsar20 February 2026AY 2013-14Bench: HON’BLE SHRI MANOJ KUMAR AGGARWAL (Accountant Member), SHRI UDAYAN DASGUPTA (Judicial Member)5 pages
AI SummaryDismissed

What did the Tribunal hold?

The tribunal upheld the Pr. CIT's revisional jurisdiction under Section 263, finding that the Assessing Officer failed to examine the incorrect computation of book profits under Section 115JB. The non-examination of this issue by the AO made the order erroneous and prejudicial to the revenue, justifying the invocation of Explanation-2 to Section 263(1).

What were the facts?

The assessee's assessment was completed under Section 143(3). The Pr. CIT later found that the assessee had incorrectly claimed a deduction under Section 80IB while computing book profits under Section 115JB, leading to a short computation of book profit. The Pr. CIT invoked revisional jurisdiction under Section 263, holding the assessment order erroneous and prejudicial to the revenue.

What were the issues?

The key legal issue was the validity of the Pr. CIT's revisional jurisdiction under Section 263 for the AO's failure to correctly compute book profits under Section 115JB by allowing an impermissible deduction under Section 80IB.

Which sections of the Income-tax Act were involved?

Section 263,Section 143(3),Section 80IB,Section 115JB,Section 263(1),Section 154,Section 264

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, “DB” BENCH, AMRITSAR

Before: HON’BLE SHRI MANOJ KUMAR AGGARWAL, AM & SHRI UDAYAN DASGUPTA, JM

Pronounced: 20.02.2026

Manoj Kumar Aggarwal (Accountant Member)

1.

In this appeal for Assessment Year (AY) 2013-14, the assessee challenges exercise of revisional juri iction u/s 263 by Ld. Pr. Commissioner of Income Tax-1, Jalandhar (Pr. CIT) vide order dated 30-03-2018. 2. The Ld. AR appeared virtually and sought adjournment. However, keeping in mind the fact that this appeal was filed way back in the year 2019 and it is an old appeal, the adjournment was rejected.

Moreover, this being chal

The order continues below.

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