CIT v. Ashish Rajpal

320 ITR 674High Court2010#838 most cited

What is CIT v. Ashish Rajpal authority for?

When an assessment has been framed after an inquiry, the Commissioner cannot revise the order under Section 263 merely because the assessment order does not explicitly detail the queries raised and responses received. An order is not erroneous or prejudicial to the revenue solely because the inquiry could have been more elaborate, provided the Assessing Officer applied their mind.

124

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2011 to 2026.

Also referred to as

CIT v. Ashish Rajpal · Section 263 · revisional powers · erroneous assessment · prejudicial to interest of revenue · inadequate enquiry · lack of enquiry · application of mind · detailed enquiry · assessment order · Section 143(3)

Also reported as

180 Taxmann 62323 DTR 266

Sections most often in play

Section 263Section 143(3)Section 142(1)Section 147Section 143(2)Section 148Section 151Section 10(37)

Issues it is cited on

section 141section 282a(1)section 194lasection 145a(b)section 145binadequate enquirysection 45(5)section 57(iv)lack of enquirysection 56(2)(viii)section 263(1)prejudicial to interest of revenue

Judgments citing CIT v. Ashish Rajpal

SH. RANDHIR SINGH,SIRSA vs. PCIT ROHTAK, ROHTAK

In the result, all the above appeals filed by the respective assessee’s are dismissed

ITA 494/CHANDI/2024[2013-14]Status: DisposedITAT Chandigarh24 Feb 2026AY 2013-14

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

Section 143(3)Section 263

…inadequate that would not by itself give occasion to the Commissioner to pass orders under Section 263 of the Act, merely because he has different opinion in the matter. It is only in cases of "lack of inquiry" that such a course of action would be open.” vi) 320 ITR 674 (Del) CIT vs. Ashish Rajpal 11.7 The assessee also seeks to place reliance on the judgment of Hon’ble Delhi High Court in the case of DIT vs. Jyoti Foundation reported in 357 ITR 388 (Del) wherein it has been held as under: “4. Revisionary power under Section 263 of the Act is conferred by the Act on the Commissioner/Director of Income-tax when a…

SURJEET SINGH,SIRSA vs. PCIT, ROHTAK, ROHTAK

In the result, all the above appeals filed by the respective assessee’s are dismissed

ITA 488/CHANDI/2024[2018-19]Status: DisposedITAT Chandigarh24 Feb 2026AY 2018-19

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

Section 143(3)Section 263

…inadequate that would not by itself give occasion to the Commissioner to pass orders under Section 263 of the Act, merely because he has different opinion in the matter. It is only in cases of "lack of inquiry" that such a course of action would be open.” vi) 320 ITR 674 (Del) CIT vs. Ashish Rajpal 11.7 The assessee also seeks to place reliance on the judgment of Hon’ble Delhi High Court in the case of DIT vs. Jyoti Foundation reported in 357 ITR 388 (Del) wherein it has been held as under: “4. Revisionary power under Section 263 of the Act is conferred by the Act on the Commissioner/Director of Income-tax when a…

SH. PARAMJEET SINGH,SIRSA vs. PCIT, ROHTAK

In the result, all the above appeals filed by the respective assessee’s are dismissed

ITA 290/CHANDI/2023[2018-19]Status: DisposedITAT Chandigarh24 Feb 2026AY 2018-19

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

Section 143(3)Section 263

…inadequate that would not by itself give occasion to the Commissioner to pass orders under Section 263 of the Act, merely because he has different opinion in the matter. It is only in cases of "lack of inquiry" that such a course of action would be open.” vi) 320 ITR 674 (Del) CIT vs. Ashish Rajpal 11.7 The assessee also seeks to place reliance on the judgment of Hon’ble Delhi High Court in the case of DIT vs. Jyoti Foundation reported in 357 ITR 388 (Del) wherein it has been held as under: “4. Revisionary power under Section 263 of the Act is conferred by the Act on the Commissioner/Director of Income-tax when a…

DHUNI CHAND HUF,SIRSA vs. PCIT, ROHTAK

In the result, all the above appeals filed by the respective assessee’s are dismissed

ITA 289/CHANDI/2023[2018-19]Status: DisposedITAT Chandigarh24 Feb 2026AY 2018-19

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

Section 143(3)Section 263

…inadequate that would not by itself give occasion to the Commissioner to pass orders under Section 263 of the Act, merely because he has different opinion in the matter. It is only in cases of "lack of inquiry" that such a course of action would be open.” vi) 320 ITR 674 (Del) CIT vs. Ashish Rajpal 11.7 The assessee also seeks to place reliance on the judgment of Hon’ble Delhi High Court in the case of DIT vs. Jyoti Foundation reported in 357 ITR 388 (Del) wherein it has been held as under: “4. Revisionary power under Section 263 of the Act is conferred by the Act on the Commissioner/Director of Income-tax when a…

SH. KASHMIR SINGH SANDHA,SIRSA vs. PCIT, ROHTAK

In the result, all the above appeals filed by the respective assessee’s are dismissed

ITA 288/CHANDI/2023[2018-19]Status: DisposedITAT Chandigarh24 Feb 2026AY 2018-19

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

Section 143(3)Section 263

…inadequate that would not by itself give occasion to the Commissioner to pass orders under Section 263 of the Act, merely because he has different opinion in the matter. It is only in cases of "lack of inquiry" that such a course of action would be open.” vi) 320 ITR 674 (Del) CIT vs. Ashish Rajpal 11.7 The assessee also seeks to place reliance on the judgment of Hon’ble Delhi High Court in the case of DIT vs. Jyoti Foundation reported in 357 ITR 388 (Del) wherein it has been held as under: “4. Revisionary power under Section 263 of the Act is conferred by the Act on the Commissioner/Director of Income-tax when a…

M/S GANESH DASS HUF,SIRSA vs. PCIT, ROHTAK

In the result, all the above appeals filed by the respective assessee’s are dismissed

ITA 287/CHANDI/2023[2018-19]Status: DisposedITAT Chandigarh24 Feb 2026AY 2018-19

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

Section 143(3)Section 263

…inadequate that would not by itself give occasion to the Commissioner to pass orders under Section 263 of the Act, merely because he has different opinion in the matter. It is only in cases of "lack of inquiry" that such a course of action would be open.” vi) 320 ITR 674 (Del) CIT vs. Ashish Rajpal 11.7 The assessee also seeks to place reliance on the judgment of Hon’ble Delhi High Court in the case of DIT vs. Jyoti Foundation reported in 357 ITR 388 (Del) wherein it has been held as under: “4. Revisionary power under Section 263 of the Act is conferred by the Act on the Commissioner/Director of Income-tax when a…

SH. ARVAIL SINGH,SIRSA vs. PCIT, ROHTAK

In the result, all the above appeals filed by the respective assessee’s are dismissed

ITA 286/CHANDI/2023[2018-19]Status: DisposedITAT Chandigarh24 Feb 2026AY 2018-19

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

Section 143(3)Section 263

…inadequate that would not by itself give occasion to the Commissioner to pass orders under Section 263 of the Act, merely because he has different opinion in the matter. It is only in cases of "lack of inquiry" that such a course of action would be open.” vi) 320 ITR 674 (Del) CIT vs. Ashish Rajpal 11.7 The assessee also seeks to place reliance on the judgment of Hon’ble Delhi High Court in the case of DIT vs. Jyoti Foundation reported in 357 ITR 388 (Del) wherein it has been held as under: “4. Revisionary power under Section 263 of the Act is conferred by the Act on the Commissioner/Director of Income-tax when a…

SRI RAMASEVA BAHUSARA KSHARIYA CO-OP. SOCIETY LIMITED,SHIMOGA vs. PR. CIT, BENGALURU-1, BENGALURU

In the result the appeal filed by the assessee is allowed

ITA 861/BANG/2025[2020-21]Status: DisposedITAT Bangalore30 Jan 2026AY 2020-21

Bench: Shri Prashant Maharishi & Shri Keshav Dubeyassessment Year : 2020-21 M/S. Sri Ramaseva Bahusara Kshariya Co-Op. Society Ltd. 01, Ramanna Setty Park Spm Road, Doddapete So Vs. Principal Cit Shimoga 577 202 Bengaluru-1 Karnataka Pan No :Aaajs0083P Appellant Respondent Appellant By : Sri V. Srinivasan, A.R. Respondent By : Sri Kiran D., D.R. Date Of Hearing : 11.12.2025 Date Of Pronouncement : 30.01.2026

For Appellant: Sri V. Srinivasan, A.RFor Respondent: Sri Kiran D., D.R
Section 143(1)Section 143(2)Section 143(3)Section 263Section 80PSection 80P(2)(a)

…ial to the assessee, rendered by the jurisdictional High Court or Supreme Court in the case of the assessee or any other person.” 7.10 The Hon’ble High Court of Delhi in the case of Commissioner of Income-tax- XIII v. Ashish Rajpal reported in (Del-HC) (2010) 320 ITR 674 had remarkably extracted the parameters and principles laid down by the Courts which govern the exercise power by the Commissioner under the provisions of section 263 of the Act:- (i) The power is supervisory in nature, whereby the Commissioner can call for and examine the assessment records (ii) The Commissioner can revise the assessment order i…

BHARATH CREDIT CO-OPERATIVE SOCIETY LIMITED ,BANGALORE vs. PR. CIT, BANGALORE -1, BANGALORE

In the result the appeal filed by the assessee is allowed

ITA 788/BANG/2025[2020-21]Status: DisposedITAT Bangalore30 Jan 2026AY 2020-21

Bench: Ms. Padmavathy S. & Shri Keshav Dubeyassessmentyear:2020-21

For Appellant: Sri Ravishankar S.V., A.RFor Respondent: Sri Shivanand H Kalakeri, D.R
Section 139(1)Section 142(1)Section 143(1)Section 143(2)Section 143(3)Section 263Section 56Section 80P(2)Section 80P(2)(a)

…upreme Court in the case of the assessee or any other person.” Bharath Credit Co-operative Society Limited, Bengaluru Page 18 of 30 7.10 The Hon’ble High Court of Delhi in the case of Commissioner of Income-tax-XIII v.Ashish Rajpal reported in (Del-HC) (2010) 320 ITR 674 had remarkably extracted the parameters and principles laid down by the Courts which govern the exercise power by the Commissioner under the provisions of section 263 of the Act:- The power is supervisory in nature, whereby the Commissioner can call for (i) and examine the assessment records. The Commissioner can revise the assessment order if t…

SUBHASH JAISWAL ASSOCIATES,BAREILLY vs. PCIT BAREILLY, BAREILLY

ITA 100/LKW/2022[2017-18]Status: DisposedITAT Lucknow11 Dec 2025AY 2017-18
Section 143(3)Section 263

…{ "clean_text": "IN THE INCOME TAX APPELLATE TRIBUNAL\nLUCKNOW BENCH “B”, LUCKNOW\nBEFORE SHRI ANADEE NATH MISSHRA, ACCOUNTANT MEMBER\nAND SHRI SUBHASH MALGURIA, JUDICIAL MEMBER\nITA No.100/LKW/2022\n(Assessment Year: 2017-18)\n\nSubhash Jaiswal Associates\n71, Newada Sheikhan, Bareilly,\nUttar Pradesh-243001.\nPAN:AAMAS7252B\n(Appellant)\nAppellant by:\nRespondent by:\nV.\nShri Devinder Singh\nKalyan,\nPCIT, Bareilly, Uttar\nPradesh-243001.\n(Respondent)\nShri Rakesh Garg, Advocate\nShri R. R. N. Shukla, Addl. CIT(DR)\nORDER\nPER ANADEE NATH MISSHRA, A.M.:\n(A) Vide ITA. No.100/LKW/2022 appeal has been filed b…

BHAVANA CO-OP CREDIT SOCIETY NIYAMITA ,SIRSI vs. INCOME TAX OFFICER, WARD-1, SIRSI

In the result the appeal filed by the assessee is allowed

ITA 1074/BANG/2025[2020-21]Status: DisposedITAT Bangalore03 Dec 2025AY 2020-21

Bench: Shri Prashant Maharishi & Shri Keshav Dubeyassessment Year : 2020-21

For Appellant: Sri V. Srinivasan, A.RFor Respondent: Sri Shivanand H Kalakeri, D.R
Section 142(1)Section 143(2)Section 143(3)Section 263Section 80P(2)(a)Section 80P(2)(i)

…ITANo.1074/Bang/2025 M/s. Bhavana Co op Credit Society Niyamitha, Sirsi IN THE INCOME TAX APPELLATE TRIBUNAL “A’’BENCH: BANGALORE BEFORE SHRI PRASHANT MAHARISHI,VICE PRESIDENT AND SHRI KESHAV DUBEY, JUDICIAL MEMBER Assessment Year : 2020-21 M/s. Bhavana Co-op. Credit Society Niyamita #38, Market Road Principal CIT Vs. Sirsi 581 401 Hubali PAN NO :AACAB5033D APPELLANT RESPONDENT Assessment Year : 2020-21 M/s. Gonikoppal Primary Rural Agricultural Credit Co-operative Society Ltd. Main Road, Gonikoppal Principal CIT Vs. Virajpet Taluk Bengaluru-3 Kodagu 571 213 PAN NO : AAAAG1109M APPELLANT RESPONDENT Appel…

GONIKOPPAL PRIMARY RURAL AGRICULTURAL CREDIT CO-OPERATIVE SOCIETY LIMITED ,KODAGU vs. PR. COMMISSIONER OF INCOME TAX, BENGALURU-3, BENGALURU

In the result the appeal filed by the assessee is allowed

ITA 1072/BANG/2025[2020-21]Status: DisposedITAT Bangalore03 Dec 2025AY 2020-21

Bench: Shri Prashant Maharishi & Shri Keshav Dubeyassessment Year : 2020-21

For Appellant: Sri V. Srinivasan, A.RFor Respondent: Sri Shivanand H Kalakeri, D.R
Section 142(1)Section 143(2)Section 143(3)Section 263Section 80P(2)(a)Section 80P(2)(i)

…ITANo.1074/Bang/2025 M/s. Bhavana Co op Credit Society Niyamitha, Sirsi IN THE INCOME TAX APPELLATE TRIBUNAL “A’’BENCH: BANGALORE BEFORE SHRI PRASHANT MAHARISHI,VICE PRESIDENT AND SHRI KESHAV DUBEY, JUDICIAL MEMBER Assessment Year : 2020-21 M/s. Bhavana Co-op. Credit Society Niyamita #38, Market Road Principal CIT Vs. Sirsi 581 401 Hubali PAN NO :AACAB5033D APPELLANT RESPONDENT Assessment Year : 2020-21 M/s. Gonikoppal Primary Rural Agricultural Credit Co-operative Society Ltd. Main Road, Gonikoppal Principal CIT Vs. Virajpet Taluk Bengaluru-3 Kodagu 571 213 PAN NO : AAAAG1109M APPELLANT RESPONDENT Appel…

SANJAY CHAWLA,CHAIBASA vs. PR. CIT, RANCHI

In the result, the appeal of the assessee is allowed

ITA 135/RAN/2025[20-21]Status: DisposedITAT Ranchi07 Oct 2025

Bench: Shri George Mathan & Shri Ratnesh Nandan Sahaysanjay Chawla, Pr.C.I.T., Sentola, Chaibasa-833201 (Jharkhand) Ranchi. Vs. Pan No. Acmpc 6808 J Appellant/ Assessee Respondent/ Revenue

Section 142(1)Section 143(2)Section 143(3)Section 2Section 263Section 63

…s not agree with and which results in a loss of revenue, it cannot be treated as erroneous order prejudicial to the interest of revenue, unless the view taken by the Assessing Officer is completely unsustainable in law." CIT v. Ashish Rajpal (2009) 23 DTR 266/320 ITR 674/180 Taxman 623 (Delhi) (High Court) – Where the assessing officer during the scrutiny assessment proceeding raised a query which was answered by the assessee to the satisfaction of the assessing officer but the same was not reflected in the assessment order by him, a conclusion cannot be 4 Sanjay Chawla Vs PCIT drawn by the Commissioner that no p…

SHA PRATAPCHAND PUKHARAJ AND COMPANY ,VIJAYAPUR vs. INCOME TAX OFFICER, WARD-1 & TPS, , BIJAPUR

In the result, the appeal of the assessee is allowed

ITA 2547/BANG/2024[2017-18]Status: DisposedITAT Bangalore15 Sept 2025AY 2017-18

Bench: Shri Waseem Ahmed & Shri Keshav Dubeyassessment Year : 2017-18

For Appellant: Smt. Pratibha R., A.RFor Respondent: Sri Subramanian S., D.R
Section 253Section 253(5)Section 263

…ITA No.2547/Bang/2024 Sha Pratapchand Pukhraj and Company, Vijayapur IN THE INCOME TAX APPELLATE TRIBUNAL “B’’BENCH: BANGALORE BEFORE SHRI WASEEM AHMED, ACCOUNTANT MEMBER AND SHRI KESHAV DUBEY, JUDICIAL MEMBER Assessment Year : 2017-18 Sha Pratapchand Pukhraj and Company C/o Shri S. Parthasarathi, Advocate No.3/1, ‘Pranava Complex’ PCIT Vs. 5th Cross, Malleswaram Hubballi Bangalore 560 003 PAN NO :AADFS9212M APPELLANT RESPONDENT Appellant by : Smt. Pratibha R., A.R. Respondent by : Sri Subramanian S., D.R. Date of Hearing : 18.06.2025 Date of Pronouncement : 15.09.2025 O R D E R PER KESHAV DUBEY, JUDICIAL…

VANIGOTA SUGAR TRADING COMPANY ,VIJAPUR vs. INCOME TAX OFFICER, WARD-1 & TPS , BIJAPUR

In the result, the appeal of the assessee is allowed

ITA 2545/BANG/2024[2017-18]Status: DisposedITAT Bangalore15 Sept 2025AY 2017-18

Bench: Shri Waseem Ahmed & Shri Keshav Dubeyassessment Year : 2017-18

For Appellant: Smt. Pratibha R., A.RFor Respondent: Sri Subramanian S., D.R
Section 253(5)Section 263

…ITA No.2545/Bang/2024 Vanigota Sugar Trading Company, Vijaypur IN THE INCOME TAX APPELLATE TRIBUNAL “B’’ BENCH: BANGALORE BEFORE SHRI WASEEM AHMED, ACCOUNTANT MEMBER AND SHRI KESHAV DUBEY, JUDICIAL MEMBER Assessment Year : 2017-18 Vanigota Sugar Trading Company C/o Sri S. Parthasarathi, Advocate No.3/1, “Pranava Complex” 5th Cross, Malleswaram Vs. PCIT Bangalore 560003 Hubballi PAN NO : AAAFV8614K APPELLANT RESPONDENT Appellant by : Smt. Pratibha R., A.R. Respondent by : Sri Subramanian S., D.R. Date of Hearing : 18.06.2025 Date of Pronouncement : 15.09.2025 O R D E R PER KESHAV DUBEY, JUDICIAL MEMBER: T…

ALLIANCE NIRMAAN LIMITED,BAREILLY vs. PCIT, BAREILLY

In the result, the appeal of the assessee is allowed

ITA 119/LKW/2022[2017-18]Status: DisposedITAT Lucknow12 Jun 2025AY 2017-18
Section 143(3)Section 263

…ed and\nwhen assessment has been framed after inquiry and there is no error in the order, then the order\ncannot be revised on the ground that inquiry should have been more detailed or elaborate.\nHon'ble Delhi High Court in the case of Ashish Rajpal - [2009] 320 ITR 674 order\npronounced on 14.05.2009 HEAD NOTE \"Section 263 of the Income-tax Act, 1961 -\nRevision Of orders prejudicial to interest of revenue Assessment year 2002-03 - Whether\nmerely because an assessment order does not refer to queries raised by Assessing Officer during\ncourse of scrutiny and response of assessee thereto, it can be said that th…

THE PR. COMMISSIONER OF INCOME-TAX vs. M/S. TE CONNECTIVITY INDIA PVT. LTD.,

Accordingly dispose of the appeal as allowed

ITA/53/2024HC Karnataka05 Jun 2025

Bench: ACTING CHIEF JUSTICE,S RACHAIAH

Section 143(2)Section 143(3)Section 144C(13)Section 260ASection 263Section 40

…- 1 - ITA No.53 of 2024 IN THE HIGH COURT OF KARNATAKA AT BENGALURU DATED THIS THE 5TH DAY OF JUNE, 2025 PRESENT THE HON'BLE MR V KAMESWAR RAO, ACTING CHIEF JUSTICE AND THE HON'BLE MR JUSTICE S RACHAIAH ITA NO. 53 OF 2024 BETWEEN: 1 . THE PR. COMMISSIONER OF INCOME-TAX, 5TH FLOOR, BMTC BUILDING, 80 FEET ROAD, KORMANGALA, BENGALURU - 560 095. 2 . THE PR. COMMISSIONER OF INCOME TAX-2, PRESENT ADDRESS, DCIT, CIRCLE-7(1)(1), 2ND FLOOR, BMTC BUILDING, 80 FEET ROAD, KORMANGALA, BENGALURU - 560 095. ...APPELLANTS (BY SRI. SUSHAL TIWARI N, ADVOCATE) AND: M/S. TE C…

DEVPRABHA CONSTRUCTION PRIVATE LTD.,,DHANBAD vs. PCIT, DHANBAD

In the result, this appeal of the assessee is allowed

ITA 27/RAN/2024[2018-19]Status: DisposedITAT Ranchi30 May 2025AY 2018-19

Bench: Shri George Mathan & Shri Ratnesh Nandan Sahay(Virtual Hearing) Devprabha Construction Private Ltd., P.C.I.T., Dev Villa, Behind Radha Swamy Arcade, Dhanbad, Vs. Saraidhela, Dhanbad-828127. Aayakar Bhawan, Luby Pan No. Aaecb 2652 A Circular Road, Dhanbad-826001 (Jharkhand) Appellant/ Assessee Respondent/ Revenue

Section 133(6)Section 143(3)Section 263

…ties. That merely because AO formed an opinion in favour of the assessee and did not record the same in the order of assessment, will not render the assessment to be erroneous and prejudicial to the interest of revenue. CIT V. Ashish Rajpal (2009) 23 DTR 266/ 320 ITR 674/180 Taxman 623 (Delhi) (High Court) - Where the assessing officer during the scrutiny assessment proceeding raised a query which was answered by the assessee to the satisfaction of the assessing officer but the same was not reflected in the assessment order by him, a conclusion cannot be drawn by the Commissioner that no proper enquiry with respe…

GENUS POWER INFRASTRUCTURES LIMITTED,NOIDA vs. PR. COMMISSIONER OF INCOME TAX(CENTERAL), LUCKNOW

ITA 74/LKW/2022[2016-17]Status: DisposedITAT Lucknow18 Mar 2025AY 2016-17

Bench: Shri Kul Bharat & Shri Anadee Nath Misshra

For Appellant: Respondent byFor Respondent: Shri Praveen Kumar, Adv
Section 143(3)Section 263Section 35

…vs.CIT,243 ITR 83(S.C.); CIT vs. Hindustan Coca-Cola Beverages (P) Ltd. 331 ITR 192 (Del.); CIT vs. International Travel House Lid. 194 Тахтап 324; CIT vs. DLF Power Limited 329 ITR 289 (Del.); CIT vs. Eicher Limited 294 ITR 310 (Del.) CIT vs. Ashish Rajput, 320 ITR 674 (Del.); CIT vs. Rohit Anand, 327 ITR 445 (Del.); CIT vs. Gopal Purohit, 228 CTR 582 (Bom.); and CIT vs. PNB Finance and Industries Limited, 236 CTR 1 (Del.).…

SBS BIOTECH UNIT II,SIRMOUR vs. PRINCIPAL COMMISSIONER OF INCOME TAX-1, CHANDIGARH

In the result, the appeal of the assessee is allowed

ITA 413/CHANDI/2024[2017-18]Status: DisposedITAT Chandigarh25 Feb 2025AY 2017-18

Bench: SHRI. VIKRAM SINGH YADAV (Accountant Member), SHRI. PARESH M. JOSHI (Judicial Member)

For Appellant: Shri Ajay Jain, C.AFor Respondent: Shri Abhishek Pal Garg, DR
Section 143(1)Section 143(2)Section 147Section 148Section 263Section 801CSection 80I

…quiry with respect to the issue was made by the AO, and enable him to assume jurisdiction under section 263 of the Act and reliance was placed on the following judicial decisions:  Hari Iron Trading Company vs CIT 2003 (5) TMI 48 (P&H)  Ashish Rajpal [2009] 320 ITR 674 (Delhi)  Vikash Polymers [2010] 194 Taxman 57 (Delhi)  Krishna Capbox (P.) Ltd. (2015) 60 taxmann.com 243 (All) 13. Thus, where the Assessing Officer has made necessary enquiry and applied his mind, Commissioner cannot exercise his revisional powers under section 263 of the Act. It was submitted that non-passing of elaborated order does not tan…

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CIT v. Ashish Rajpal (320 ITR 674) — Cited in 124 Judgments | BharatTax