AMARENDRA FINANCIAL PVT.LTD.,NEW DELHI vs. PR. CIT (CENTRAL) KNP , MEERUT

ITA 2526/DEL/2024Status: DisposedITAT Delhi26 September 2025AY 2016-17Bench: the tribunal. Before us, assessee also take additional grounds of appeal which are admitted as they are purely legal in nature and requires no verification of facts by placing reliance on the judgment of hon'ble Supreme Court in the case of NTPC Ltd. reported in 229 ITR 383(SC).9 pages
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What did the Tribunal hold?

The Tribunal held that the Principal CIT lacked jurisdiction to revise the assessment order under Section 263 because the issues forming the basis of the revision were already pending before the CIT(A). Therefore, the revisionary order was quashed.

What were the facts?

The assessee's assessment order, which included additions on a protective basis, was revised by the Principal CIT under Section 263. The assessee had already filed an appeal before the CIT(A) challenging these additions.

What were the issues?

Whether the Principal CIT can exercise revisionary powers under Section 263 when the assessment order's issues are already under appeal before the CIT(A)? Does Explanation 1(c) to Section 263 bar revision when an appeal is pending?

Which sections of the Income-tax Act were involved?

Section 263,Section 153C,Section 143(3),Section 68,Section 69A

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Cases cited in this judgment(4)Show list

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Income Tax Appellate Tribunal, DELHI BENCH ‘A’: NEW DELHI

For Appellant: Smt. Rano Jain, Adv, Ms. Mansi Jain, CA and Shri Pranshu Singhal, CA
Hearing: 08/07/2025Pronounced: 26/09/2025

PER MANISH AGARWAL, AM: This appeal is filed by the assessee against the order of Ld. Principal Commissioner of Income Tax (Central), KNP at Meerut [PCIT, in short] passed u/s 263 of the Income Tax Act, 1961 dated 31.03.2024 for Assessment Year 2016-17. 2. Brief facts of the case are that return of income was e-filed by the assessee on 16.10.2016, declaring total income at Rs.28,69,100/-. A search and seizure action was carried on 11.10.2018 at the premises of the group company cases wherein it was found that certain information/documents were belonged to assessee and therefore, proceedings u/s 153C of the Act were initiated in the case Amare

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