DAVINDER KUMAR MAGO,PUNJABI BAGH vs. DCIT/ACIT CENTRAL CIRCLE, DDN, DEHRADUN

ITA 17/DDN/2026Status: DisposedITAT Dehradun12 March 2026AY 2019-20Bench: SHRI MAHAVIR SINGH (Vice President), SHRI MANISH AGARWAL (Accountant Member)9 pages
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What did the Tribunal hold?

The Tribunal held that the AO had made proper and adequate inquiries and verification regarding the genuineness and creditworthiness of the loan transactions and lenders. The Pr.CIT failed to point out any error or omission in the details provided by the assessee, thus quashing the revision order.

What were the facts?

The assessee's case was reopened, and the Assessing Officer (AO) accepted the declared income. Subsequently, the Pr.CIT initiated revision proceedings under Section 263, holding the assessment order erroneous and prejudicial to the revenue's interest due to alleged inadequate inquiries regarding unsecured loans.

What were the issues?

The key legal issue was whether the Pr.CIT was justified in invoking Section 263 to revise the assessment order, claiming 'inadequate inquiries' by the AO regarding unsecured loans, despite the assessee providing detailed documentation.

Which sections of the Income-tax Act were involved?

Section 263,Section 143(3),Section 147,Section 142(1)

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Cases cited in this judgment(3)Show list

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Income Tax Appellate Tribunal, DEHRADUN “DB” BENCH: DEHRADUN

Before: SHRI MAHAVIR SINGH & SHRI MANISH AGARWAL

For Appellant: Shri Ajay Wadhwa, Adv. (VC)
For Respondent: Ms. Poonam Sharma, CIT DR
Hearing: 10.03.2026Pronounced: 12.03.2026

PER MANISH AGARWAL, AM : This appeal filed by the assessee against the order by Pr.CIT (Central), Kanpur at Meerut passed u/s 263 of the Income Tax Act, 1861 (“the Act”) dated 08.01.2026 arising out of the order passed u/s 143(3) r.w.s. 147 of the Act.

2.

Brief facts of the case are that the assessee is an individual, a search action was carried out in the case of the assessee on 24.11.2022. Thereafter, the case of the assessee was re-opened by issue of notice u/s 147 of the Act. The reassessment order was passed wherein income declared by the assessee is accepted by AO. Thereafter, based on the information provided by the AO himself, Ld. PCIT initiated revision proceedings u/s 263 of the Act and

The order continues below.

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