Which sections of the Income Tax Act does CIT v. Shree Manjunathesware Packing Products come up under?

It is most often cited in judgments turning on Section 263, Section 143(3), Section 147, Section 148, Section 151, Section 10(37).

CIT v. Shree Manjunathesware Packing Products

Q: How many judgments cite CIT v. Shree Manjunathesware Packing Products?

163 judgments on BharatTax cite CIT v. Shree Manjunathesware Packing Products (231 ITR 53), spanning 2012 to 2026.

231 ITR 53Supreme Court of India1998#602 most cited

What is CIT v. Shree Manjunathesware Packing Products authority for?

The term 'record' under Section 263(1) of the Income Tax Act includes all material available to the Commissioner at the time of his examination, not merely the records that were available to the Assessing Officer when the original assessment order was passed.

163

judgments rely on this decision, according to BharatTax’s citation analysis of 366,369 Indian tax judgments — from 2012 to 2026.

Also referred to as

CIT v. Shree Manjunathesware Packing Products · Section 263 · meaning of record · revisional power · material available to Commissioner · erroneous and prejudicial · inadequate enquiry · 231 ITR 53 · scope of 263(1) · examination by CIT

Sections most often in play

Section 263 Section 143(3)Section 147 Section 148 Section 151 Section 10(37)Section 142(1)Section 145A(b)

Issues it is cited on

inadequate enquiry lack of enquiry doctrine of merger section 263(1)malabar industrial revision u/s 263 non application of mind erroneous and prejudicial mercantile system of accounting section 263 section 26 income-tax officer

Judgments citing CIT v. Shree Manjunathesware Packing Products

Sushila Bhaurao Deshmukh, Amravati vs. Principal Commissioner of Income Tax-1, Nagpur

In the result, appeal filed by the assessee is allowed

ITA 76/NAG/2022[2017-18]Status: DisposedITAT Nagpur20 Sept 2024AY 2017-18

Bench: Shri V. Durgarao & Shrik.M. Roy, Accountant, Member

For Appellant: ShriK.P. DewaniFor Respondent: Shri Sandeep Salunke

Section 143(3)Section 263Section 263(1)Section 54BSection 54E

…h the CIT can rely includes not only the record as it stands at the time when the order in question was passed by the Assessing Officer but also the record as it stands at the time of examination by the CIT [see CIT vs. Shree Manjunathesware Packing Products, 231 ITR 53 (SC)]. Nothing bars/prohibits the CIT from collecting and relying upon new/additional material/evidence to show and state that the order of the Assessing Officer is erroneous. 18. It is in this context that the Supreme Court in Malabar Industrial Co. Ltd. vs. Commissioner of Income Tax, (2000) 243 ITR 83 (SC), had observed that the phrase "prejudi…

M/S. Ganga Electricals, Nashik vs. Principal Commissioner of Income-Tax.-1, Nashik

In the result, the appeal filed by the assessee is allowed

ITA 215/PUN/2022[2017-18]Status: DisposedITAT Pune26 Jul 2024AY 2017-18

Bench: Shri Rama Kanta Panda & Ms. Astha Chandra

For Appellant: Shri Sanket M. JoshiFor Respondent: Shri Pankaj Kumar

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

…h the CIT can rely includes not only the record as it stands at the time when the order in question-was passed by the Assessing Officer but also the record as it stands at the time of examination by the CIT [see CIT vs. Shree Manjunathesware Packing Products, 231 ITR 53 (SC)]. Nothing bars/prohibits the CIT from collecting and relying upon new/additional material/evidence to show and state that the order of the Assessing Officer is erroneous.” 27. We find the Mumbai Bench of the Tribunal in the case of DK Associates has observed as under : “We have examined Explanation 2 to section 263 which is inserted by the…

Idemia Syscom India Private Limited, Noida vs. CIT(Tp), Delhi-2, New Delhi

In the result, the appeal of the assessee in ITA No

ITA 647/DEL/2024[2020-21]Status: DisposedITAT Delhi28 Mar 2024AY 2020-21

Bench: Shri Saktijit Dey & Shri N.K. Billaiya

For Appellant: Shri M.S. Syali, Sr. AdvFor Respondent: Shri Rajesh Kumar, CIT- DR

Section 263Section 92C

…IN THE INCOME TAX APPELLATE TRIBUNAL, DELHI ‘I’ BENCH, NEW DELHI BEFORE SHRI SAKTIJIT DEY, VICE PRESIDENT, AND SHRI N.K. BILLAIYA, ACCOUNTANT MEMBER ITA No. 647/DEL/2024 [A.Y. 2020-21] M/s Idemia Syscom India Pvt Ltd Vs. The C.I.T. Plot No. 1-A, Sector - 73 (TP) Noida, Basi Bahuddin Nagar Delhi – 2, Uttar Pradesh. PAN – AABCS 2000 C (Applicant) (Respondent) Assessee By : Shri M.S. Syali, Sr. Adv Shri Mukesh Bhutani, Adv Shri Tarandeep Singh, Adv Shri Nikky, Jhtamtani, CA Shri Sandeep Yadav, Adv Shri Saurabh Nandy, Adv Department By : Shri Rajesh Kumar, CIT- DR Date of Hearing : 14.03.2024 Date of Pron…

M/S. Rdc Ventures, Mumbai vs. PCIT-27, Mumbai

In the result, the appeal of the assessee is partly allowed

ITA 1915/MUM/2023[2018-19]Status: DisposedITAT Mumbai09 Feb 2024AY 2018-19

Bench: Shri Vikas Awasthy & Shri Amarjit Singhm/S Rdc Ventures Vs. Principal Commissioner Office No.-110 Of Income Tax-27 Ridhhisidhhi Premises Room No. 401, 4 Th Floor, Society, Near Sahakar Tower No. 6, Vashi Talkies Tilak Nagar, Railway Station, Chembur (West) Mumbai- Commercial Complex, 400089 Vashi, Navi Mumbai -400703 स्थायी लेखा सं./जीआइआर सं./Pan/Gir No:Aakfr0914Q Appellant .. Respondent Appellant By : Dhran Gandhi Respondent By : Sanyogita Nagpal Date Of Hearing 29.11.2023 Date Of Pronouncement 09.02.2024

For Appellant: Dhran GandhiFor Respondent: Sanyogita Nagpal

Section 143(2)Section 143(3)Section 263

…v. 132 taxmann.com 231 (Del) Abha Bansal vs. PCIT) vi. (1996) 57 ITD 328 (Bom) Trustees of Parsi Panchayat Funds & Properties vs. DIT] vii. Hon'ble Telangana High Court judgment in [2023] 156 taxmann.com 178 (Tel) Kankanala Ravindra Reddy vs. ITO viii. [1998] 231 ITR 53 (SC) CIT vs. Shree Manjunathesware Packing Products & Camphor Works. ix. 346 ITR 443 (Bom) Ghanshyam K. Khabrani vs. ACIT: 17. On the other hand, the ld. D.R has vehemently contended that the Pr.CIT-27, Mumbai had territorial jurisdiction over the case and correctly exercised the power to invoke provision of Sec. 263 of the Act. The ld. D.R has ma…

M/S. S.R. Ferro Alloys, Jhabua vs. The PCIT, Bhopal

In the result, the appeal of assessee is allowed

ITA 148/IND/2021[2015-16]Status: DisposedITAT Indore09 Nov 2023AY 2015-16

Bench: Shri Vijay Pal Rao & Shri B.M. Biyanis.R. Ferro Alloys Pr. Cit, Central 9, Siddheswar Colony Bhopal Vs. Jhabua (Appellant / Assessee) (Revenue) Pan: Abhfs7377Q Appellant By Shri Sumit Nema, Sr. Adv. & Gagan Tiwari, Ar Revenue By Shri Ashish Porwal, Sr. Dr Date Of Hearing 12.10.2023 Date Of Pronouncement 09.11.2023

Section 263

…cludes not only the record as it stands at the time when the order in question was passed by the Assessing Officer but also the record as it stands at the time of examination by the CIT [see CIT v. Shree Manjunathesware Packing & Products Camphor Works [1998/ 231 ITR 53/98 Taxman 1 (SC)]. Nothing bars/prohibits the CIT from collecting and relying upon new/additional material/evidence to show and state that the order of the Assessing Officer is erroneous. 18. It is in this context that the Supreme Court in Malabar Industrial Co. Ltd. v. Commissioner of Income Tax, [2000] 243 ITR 83/109 Taxman 66 (SC), had observed…

Nahar Colours and Coatinhgs Private Limited, Udaipur vs. Principal Commissioner Ofincometax, Udaipur

In the result, appeal of the assessee is allowed

ITA 140/JODH/2023[2018-19]Status: DisposedITAT Jodhpur09 Aug 2023AY 2018-19

Section 142(1)Section 143(1)Section 143(2)Section 143(3)Section 263Section 801ASection 80I

…nd Coatings Private Ltd enquiry, there is no reason why the material which had already come on record though subsequent to the making of the assessment, cannot be taken into consideration by him. (CIT v. Manjunathesware Packing Products & Camphor Works [1998] 231 ITR 53/96 Taxman 1 (SC)) 9. REVISION OF ORDER UNDER 263 WITH REFERENCE TO SECTION 14A 9.1. Main operating portion is sub-section (1) of Section 14A and the subsequent amendments has not changed the wordings of sub section (1). The Finance Act, 2006 has introduced w.e.f. 1.4.2007, sub section (2) and sub section (3) of section 14A. The sub section (2) o…

Ortem Suppliers Pvt. Ltd., Kolkata vs. PCIT-2, Kol, Kolkata

In the result, the appeal of the assessee stands dismissed

ITA 500/KOL/2023[2018-19]Status: HeardITAT Kolkata07 Jul 2023AY 2018-19

Bench: Dr. Manish Borad, Hon’Ble & Shri Sonjoy Sarma, Hon’Bleassessment Year: 2018-19 Ortem Suppliers Pvt. Ltd. Pcit - 2, Kolkata P-141, Kalindi Housing Estate, Vs. Kalindi Vatika, 4D, Block-B, Lake Town, Kolkata-700089. Pan: Aabco 2390 R (Appellant) (Respondent) Present For: Appellant By : None Respondent By : Shri S. Datta, Cit, Dr Date Of Hearing : 05.07.2023 Date Of Pronouncement : 07.07.2023 O R D E R Per Sonjoy Sarma, Jm: This Appeal Of The Assessee For The Assessment Year 2018-19 Is Directed Against The Order Of Ld. Pcit, Kolkata-2 Dated 21.03.2023 Framed U/S 263 Of The Income-Tax Act, 1961. The Assessee Has Raised Following Grounds Of Appeal: “1. That The Order Of The Ld. Pcit Is Contrary To Law & The Facts Of The Appellant Case. 2. That On The Facts & In The Circumstances Of The Case The Ld. Pcit Erred In Holding That Order Passed U/S 143(3) Dated 08-02- 2021 Is Prejudicial To The Interests Of The Revenue. 3. That On The Facts & In The Circumstances Of The Case The Ld. Pcit Erred In Disallowing Employee Contribution Of Rs. 1,53,300/- & Employer Contribution Of Rs. 1,44,998/- Made Towards Provident Fund (Pf) & Employee State Insurance Corporation (Esic). 4. That On The Facts & In The Circumstances Of The Case The Ld. Pcit Erred In Not Considering The Fact That Both Employee & Employer Contribution Aggregating Rs. 2,98,298/- Was Made Before The Due Date Of Filing Income Tax Return.

For Appellant: NoneFor Respondent: Shri S. Datta, CIT, DR

Section 143(3)Section 263Section 36Section 36(1)Section 43B

…IN THE INCOME TAX APPELLATE TRIBUNAL KOLKATA BENCH “A” KOLKATA BEFORE DR. MANISH BORAD, HON’BLE ACCOUNTANT MEMBER AND SHRI SONJOY SARMA, HON’BLE JUDICIAL MEMBER Assessment Year: 2018-19 Ortem Suppliers Pvt. Ltd. PCIT - 2, Kolkata P-141, Kalindi Housing Estate, Vs. Kalindi Vatika, 4D, Block-B, Lake Town, Kolkata-700089. PAN: AABCO 2390 R (Appellant) (Respondent) Present for: Appellant by : None Respondent by : Shri S. Datta, CIT, DR Date of Hearing : 05.07.2023 Date of Pronouncement : 07.07.2023 O R D E R PER SONJOY SARMA, JM: This appeal of the assessee for the Assessment Year 2018-19 is directed against the o…

Shri Bhawani Shankar Parashar, Indore vs. The DCIT/ACIT 1 (2), Indore

In the result, appeal of assessee is allowed

ITA 411/IND/2022[2012-13]Status: DisposedITAT Indore21 Jun 2023AY 2012-13

Bench: Shri Vijay Pal Rao & Shri B.M. Biyanishri Bhawani Shankar Pr. Cit-1 Prashar Indore 28, Lasudia Mori, Vijay Vs. Nagar, Indore (Appellant / Assessee) (Respondent/ Revenue) Pan: Bgbpp 2475 G Assessee By Shri S.N. Agrawal, Ar Revenue By Shri P.K. Mishra, Cit-Dr Date Of Hearing 02.05.2023 Date Of Pronouncement 21.06.2023

Section 263

…is of invoking the provision of section 263 of the Act. He has submitted that the Pr. CIT has relied upon the Page 9 of 21 Bhawani Shankar Page 10 of 21 judgment of Hon’ble Supreme Court in case of CIT v. Shree Manjunathesware Packing Products & Camphor Works 231 ITR 53 (SC) and therefore the impugned order is proper invalid. He has relied upon the impugned order of the Pr. CIT. 16. We have considered the rival submission as well as relevant material on record. The assessee filed his return of income on 31.03.2013 declaring total income of Rs.1,19,730/- and agricultural income of Rs.6,81,730/-. On the basis of t…

Kaur Kookies (P) Ltd., New Delhi vs. Pr, CIT, Delhi-4, New Delhi

Appeal are allowed

ITA 1119/DEL/2022[2017-18]Status: DisposedITAT Delhi11 May 2023AY 2017-18

Bench: Shri Kul Bharat & Shri Pradip Kumar Kediaassessment Year: 2017-18

Section 263Section 36

…IT can rely includes not only the record as it stands at the time when the order in question was passed by the Assessing Officer but also the record as it stands at the time of examination by the CIT [see CIT v. Shree Manjunathesware Packing Products. IT 9981 231 ITR 53 tSCVI (pages 119-125 of JPB). Nothing bars/prohibits the CIT from collecting and relying upon new/additional material/evidence to show and state that the order of the Assessing Officer is erroneous.' 5. In the present case, inquiries were certainly conducted by the Assessing Officer. It is not a case of no inquiry. The order under Section 263 itse…

M/S Shriram Properties Limited, Chennai vs. PCIT-Central1, Chennai

In the result, appeal filed by the assessee is allowed

ITA 431/CHNY/2022[2017-18]Status: DisposedITAT Chennai20 Mar 2023AY 2017-18

Bench: Shri V. Durga Rao, Hon’Ble & Shri Manjunatha. G, Hon’Bleआयकर अपील सं./Ita No.: 431/Chny/2022 िनधा"रण वष" / Assessment Year: 2017-18

For Appellant: Shri. Ananthan, CA & Ms. Lalitha. RFor Respondent: Shri. S. Senthil Kumaran, CIT

Section 143(3)Section 263Section 56(2)(vii)

…h the CIT can rely includes not only the record as it stands at the time when the order in question was passed by the Assessing Officer but also the record as it stands at the time of examination by the CIT [see CIT vs. Shree Manjunathesware Packing Products, 231 ITR 53 (SC)]. Nothing bars/prohibits the CIT from collecting and relying upon new/additional material/evidence to show and state that the order of the Assessing Officer is erroneous. :-49-: ITA. No: 431/Chny/2022 18. It is in this context that the Supreme Court in Malabar Industrial Co. Ltd. vs. Commissioner of Income Tax, (2000) 243 ITR 83 (SC), had o…

Raj Abhishek Corporation, Surat vs. Pr. CIT-1, Surat

In the result, appeal filed by the assessee is dismissed

ITA 117/SRT/2022[2017-18]Status: DisposedITAT Surat16 Jan 2023AY 2017-18

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकरअपीलसं./Ita No.117/Srt/2022 ("नधा"रणवष" / Assessment Year: (2017-18) (Physical Court Hearing) Raj Abhishek Corporation Principal Commissioner Of Income 501,Kohinoortextiles Market, Tax, Surat-1, Room No.123, Aaykar Vs. Ring Road, Surat-395002 Bhavan, Majura Gate, Surat—395002 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aajfr 6297 D (Appellant) (Respondent) िनधा"रती की ओर से /Assessee By : Shri Ketan Jagirdar, C.A राज"व क" ओर से /Respondent By : Shri Ashok B. Koli, Cit-D.R

For Appellant: Shri Ketan Jagirdar, C.AFor Respondent: Shri Ashok B. Koli, CIT-D.R

Section 143(3)Section 263Section 80Section 80I

…ch the CIT can rely includes not only the record as it stands at the time when the order in question was passed by the Assessing Officer but also the record as it stands at the time of examination by the CIT [see CIT v. Shree Manjunathesware Packing Products, 231 ITR 53 (SC)]. Nothing bars/prohibits the CIT from collecting and relying upon new/additional material/evidence to show and state that the order of the Assessing Officer is erroneous. 18. It is in this context that the Supreme Court in Malabar Industrial Co. Ltd. v. Commissioner of Income Tax, (2000) 243 ITR 83 (SC), had observed that the phrase „prejudic…

Swaran Financial Pvt Ltd., Kolkata vs. PCIT-2, Kolkata

In the result, the appeal of the assessee is allowed

ITA 192/KOL/2022[2016-17]Status: DisposedITAT Kolkata14 Dec 2022AY 2016-17

Bench: Shri Rajpal Yadav, Vice-(Kz)& Shri Rajesh Kumar]

Section 131Section 133(6)Section 139Section 143(3)Section 263Section 263(1)

…y revisionary powers have been 4 AY: 2016-17 Swaran Financial Pvt. Ltd. given to the Commissioner and such-power were held to be of; wide amplitude by the Hon’ble Supreme Court in the case of CIT v. Shree Manjunathesware Packing Products &Camphor Works [1998] 231 ITR 53/96 Taxman 1.' Therefore, normally when Assessing Officer has not made any enquiry on a particular issue, then such order in view of the above detailed discussion has to be construed as erroneous and prejudicial to the interest of Revenue and therefore, the impugned assessment order is erroneous and prejudicial to the interest of Revenue as Assessi…

Bharat Tirtha Rice Mill, Burdwan East vs. PCIT, Asansol

In the result, the appeal of the assessee is allowed

ITA 373/KOL/2022[2017-2018]Status: DisposedITAT Kolkata10 Oct 2022AY 2017-2018

Bench: Shri Rajpal Yadav, Vice-(Kz) & Shri Rajesh Kumar

Section 249Section 253Section 263Section 3Section 5

…t passed by Assessing Officer and i.e. why revisionary powers have been given to the Commissioner and such power were held to be of wide amplitude by the Hon’ble Supreme Court in the case of CIT v. Shree Manjunathesware Packing Products & Camphor Works [1998] 231 ITR 53/96 10 Assessment Year: 2017-2018 Bharat Tirtha Rice Mill Taxman 1. Therefore, normally when Assessing Officer has not made any enquiry on a particular issue, then such order in view of the above detailed discussion has to be construed as erroneous and prejudicial to the interest of Revenue and therefore, the impugned assessment order is erroneo…

Shri Sham Sunder Aggarwal, Kapurthala vs. Principal Commissioner of Income Tax -2, Kaputhala

In the result, the appeal of the assessee, ITA

ITA 410/ASR/2019[2009-10]Status: DisposedITAT Amritsar24 Aug 2022AY 2009-10

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

For Appellant: Sh. J. S. Bhasin, AdvFor Respondent: Sh. Chandrajit Singh, CIT DR

Section 143(3)Section 148Section 151Section 263

…(Calcutta)/[2016] 287 CTR 512] 9 Sham Sunder Aggarwal v. Pr. CIT 4. Rajmandir Estates (P.) Ltd. v. PCIT [2017] 77 taxmann.com 285 (SC)/[2017] 245 Taxman 127 (SC) 5. Shree Manjunathesware Packing Products & Comphor Works v. CIT [1998] 96 Taxman 1 (SC)/1998] 231 ITR 53 (SC)/[1997] 143 CTR 406 (SC) 6. Surya Jyoti Software Pvt. Ltd. v. PCIT I.T.A. No. 2158/DEL/2017) ITAT Delhi 7. Surya Financial Services Ltd. v. PCIT I.T.A. No. 2158/DEL/2017) ITAT Delhi 8. Crompton Greaves Ltd. v. CIT-6, Mumbai [2017] 82 taxmann.com 246 (Mumbai – Trib.) 9. In discussion about the assessment order, prejudicial to the interest of t…

Parvinder Kaur, Jaipur vs. PCIT-1, Jaipur

In the result, the appeal of the assessee is allowed

ITA 64/JPR/2021[2015-16]Status: DisposedITAT Jaipur01 Aug 2022AY 2015-16

For Appellant: Shri Rajeev Sogani, C.A.&For Respondent: Sh. Sanjay Dhariwal, CIT

Section 143(3)Section 263Section 54Section 54BSection 54F

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Renu Poddar, Jaipur vs. Principal Commissioner of Income Tax-2, Jaipur

In the result the appeal of the assessee is allowed

ITA 188/JPR/2022[2017-18]Status: DisposedITAT Jaipur21 Jul 2022AY 2017-18

For Appellant: Sh. Rajeev SoganiFor Respondent: Sh. Sanjay Dhariwal, CIT

Section 143(2)Section 143(3)Section 263Section 3Section 54Section 54F

…assessee or others, as well as enquiries under section 263, relevant to the issue, need to be considered for deciding the order to be erroneous and prejudicial to the interest of revenue: 18.1. Shree Manjunathesware Packing Products and Camphor Works [1998] 231 ITR 53 (SC) [CLC 26-32] 18.2. Prakashwati [2005] 144 Taxman 313 (Allahabad) [CLC 33-34] 18.3. Vallabhdas Vithaldas [2005] 56 Taxman 300 (Gujarat) [CLC 35-48] 18.4. Daga Entrade (P) Ltd [2010] 327 ITR 467 (Gauhati) [CLC 49-54] 19. Since all the evidences, from which it was discernible that the claim of the assessee was justified, were before ld. PCIT, th…

The Prajatantra Prachar Samity, Cuttack vs. ACIT, Circle-2(1), Cuttack

In the result, appeals filed by the assessee stand allowed

ITA 80/CTK/2009[1993-94]Status: DisposedITAT Cuttack09 May 2022AY 1993-94

Bench: Before S/Shri George Mathan, Judicial & Arun Khodpia & Arun Khodpia & Arun Khodpia

For Appellant: Shri S.K.Hota/Shri S.K,.AgarqwalFor Respondent: Shri S.C.Mohanty

Section 27

…g the Revenue SLP by a non-speaking order. This submission of the DR mentioned in paragraph 3 of the order has been ignored. 4. Rejection of SLP does not mean that decision of HC has been approved. CIT v. Shree Manjunatheswara Packing Products & Camphor Works 231 ITR 53 (SC). CIT v. Quality 224 ITR 77 (Pat). J. K. Charitable Trust v. WTO & Ors. 222 ITR 523 (All). 5. The order relied on by the learned AR follows the decision in the case of SSA's Emerald Meadows (SC, supra) rejecting the Revenue SLP, by a non-speaking order, against the Karnataka HC order holding no substantial question of law arising for determina…

The Prajatantra Prachar Samity, Cuttack vs. ACIT, Circle-2(1), Cuttack

In the result, appeals filed by the assessee stand allowed

ITA 79/CTK/2009[1989-90]Status: DisposedITAT Cuttack09 May 2022AY 1989-90

Bench: Before S/Shri George Mathan, Judicial & Arun Khodpia & Arun Khodpia & Arun Khodpia

For Appellant: Shri S.K.Hota/Shri S.K,.AgarqwalFor Respondent: Shri S.C.Mohanty

Section 27

The Prajatantra Prachar Samity, Cuttack vs. ACIT, Circle-2(1), Cuttack

In the result, appeals filed by the assessee stand allowed

ITA 78/CTK/2009[1985-86]Status: DisposedITAT Cuttack09 May 2022AY 1985-86

Bench: Before S/Shri George Mathan, Judicial & Arun Khodpia & Arun Khodpia & Arun Khodpia

For Appellant: Shri S.K.Hota/Shri S.K,.AgarqwalFor Respondent: Shri S.C.Mohanty

Section 27

Shobha Ramchandra Chaudhari, Yawal vs. Principle Commissioner of Income-Tax - 1, Nashik

In the result, the appeal of the assessee stands dismissed

ITA 176/PUN/2021[2016-17]Status: DisposedITAT Pune06 May 2022AY 2016-17

Bench: The A.O The Assessee Had Filed Copies Of 7/12 Extracts, Bank Account Details & Pages Of Diary, Where The Assessee Had Noted The Details Of Transactions Regarding Agricultural Income.

For Respondent: Shri Sardar Singh Meena (through physical)

Section 263

…s exempt from tax. The CIT had rightly initiated proceedings u/s 263 of the Act as exemption had been granted without application of mind. 11. It is pertinent to mention here that in the case of CIT Vs. Shree Manjunathesware Packing Products & Camphor Works, 231 ITR 53, in the context of Sec.263, Hon'ble Supreme Court held as under: "The revisionary power conferred on the CIT u/s. 263 is of wide amplitude. It enables the CIT to call for and examine the record of any proceeding under the Act. It empowers the CIT to make or cause to be made such enquiry as he deems necessary in order to find out if any order pass…