SUNITA KHANDELWAL,MUMBAI vs. PCIT-CENTRAL -1, MUMBAI
In the result, the grounds of appeal raised by the assessee are allowed
ITA 3541/MUM/2025[2019-20]Status: DisposedITAT Mumbai23 Dec 2025AY 2019-20
Bench: Shri Saktijit Dey & Shri Jagadish
For Appellant: Shri Ajay R. Singh &For Respondent: Shri Arun Kanti Datta – CIT(DR)
Section 132Section 142(1)Section 143(3)Section 153CSection 263
…plausible view and passed assessment order, Pr. Commissioner could not invoke revision jurisdiction under section 263 merely because view taken by Assessing Officer was not found acceptable to him. Hon’ble Delhi Tribunal in Amira Foods Pvt Ltd Vs PCIT (2018) 63 ITR 335 (Trib) also held that PCIT cannot treat the assessment order as erroneous and prejudicial to the interest of revenue without conducting enquiry and recording a finding of fact as to how the assessment order is erroneous. As noted earlier, the PCIT himself recorded that the assessment order appears to be erroneous without giving a clear finding, th…