CAREER POINT LIMITED,KOTA, RAJASTHAN vs. PRINCIPAL COMMISSIONER OF INCOME TAX, UDAIPUR, RAJASTHAN

PDF · subscribers
ITA 242/JPR/2023Status: DisposedITAT Jaipur22 August 2023AY 2018-19Bench: HON’BLE SHRI SANDEEP GOSAIN, JM & HON’BLE SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)53 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that the PCIT was not justified in exercising revisionary powers under Section 263. The assessment order was passed after due inquiry, and the issue of Section 14A disallowance had been decided in favour of the assessee in previous years by the ITAT.

What were the facts?

The assessee's assessment for AY 2018-19 was completed accepting the returned income. The Principal Commissioner of Income-tax (PCIT) initiated revision proceedings under Section 263, holding the assessment order erroneous and prejudicial to revenue, specifically regarding disallowance under Section 14A.

What were the issues?

Whether the PCIT was justified in revising the assessment order under Section 263 when the Assessing Officer had conducted proper inquiry and the issue was covered by previous ITAT decisions. Whether Section 14A disallowance is warranted when assessee's own funds exceed investments and no exempt income was earned.

Which sections of the Income-tax Act were involved?

Section 263,Section 14A

AI-generated summary — verify with the full judgment below

Cases cited in this judgment(30)Show list

Detected automatically from the text. Citations are also linked where they appear in the judgment. The count shows how many other judgments on BharatTax rely on the same authority.

Income Tax Appellate Tribunal, JAIPUR BENCHES,”B” JAIPUR

Before: HON’BLE SHRI SANDEEP GOSAIN, JM &

For Appellant: Shri Vijay Goyal, CA &, Shri Kapil, CA jktLo dh vksj ls@
Hearing: 25/07/2023Pronounced: 22/08/2023

vkns'kkuqlkj@ By order,

सहायक पंजीकार@Aेेज. त्महपेजतंत

More judgments on Section 263

All 13,616 judgments and leading authorities on Section 263 →

Recent GST High Court judgments

Search GST case law →