CIT v. Sohana Woollen Mills

296 ITR 238High Court2008#532 most cited

What is CIT v. Sohana Woollen Mills authority for?

A mere audit objection, by itself, is insufficient to infer that an Assessing Officer's order is erroneous or prejudicial to the interest of the Revenue for the purpose of initiating revisional proceedings.

180

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2016 to 2026.

Also referred to as

CIT v. Sohana Woollen Mills · Sohana Woollen Mills · Section 263 · revisional jurisdiction · mere audit objection · erroneous and prejudicial · prejudicial to revenue · CIT revision · PCIT revision

Issues it is cited on

Judgments citing CIT v. Sohana Woollen Mills

DHARMBATI,FARIDABAD vs. INCOME TAX INSPECTOR FARIDABAD, FARIDABAD

In the result, appeal of the assessee is allowed

ITA 5672/DEL/2025[2018-19]Status: DisposedITAT Delhi05 Mar 2026AY 2018-19

Bench: Shri Satbeer Singh Godara & Shri M. Balaganeshassessment Year: 2018-19 Dharmbati, Vs. Income Tax Inspector, H. No. 523, Chandawali, Faridabad Ballabhgarh, Faridabad Pan: Azipb6400G (Appellant) (Respondent) Assessee By None Department By Ms. Monika Singh, Cit(Dr) Date Of Hearing 05.03.2026 Date Of Pronouncement 05.03.2026 Order Per Satbeer Singh Godara, Jm This Assessee’S Appeal For Assessment Year 2018-19, Arises Against The Commissioner Of Income Tax (Appeals)/National Faceless Appeal Centre [In Short, The “Cit(A)/Nfac”], Delhi’S Din & Order No. Itba/Nfac/S/250/2025-26/1077406804(1), Dated 23.06.2025 Involving Proceedings Under Section 143(3) Of The Income-Tax Act, 1961 (Hereinafter Referred To As ‘The Act’). Case Called Twice. None Appears At The Assessee’S Behest. He Is Accordingly Proceeded Ex-Parte. 2. It Emerges During The Course Of Hearing That The Sole Substantive Issue Between The Parties Is That Of Correctness Of The Learned Lower Authorities’ Action Assessing The Assessee’S Interest Component Of Land Acquisition Compensation U/S 28 Of The Land Acquisition Act, 1894, While Invoking Section 57(Iv) R.W.S. 56(1)(A) R.W.S. 145A(B) Of The Act. 3. Learned Sr. Dr Representing The Department Vehemently Argued That The Instant Issue Is No More Res Integra In Light Of Mahender Pal Narang Vs. Cbdt (2020) 423 Itr 13 (P&H) As Well As Pcit Vs. Inderjit Singh Sodhi Huf (2024) 161 Taxmann.Com 301 (Del.) Wherein The Department Has Succeeded Before Their Lordships That The Impugned Interest Component Ought To Be Assessed As Income From “Other” Sources Only. 4. We Have Given Our Thoughtful Consideration To The Assessee’S Pleadings & Revenue’S Foregoing Vehement Contention. It Emerges That This Tribunal’S Recent Decision In Pawan Kumar Vs. Pcit (2024) 159 Taxmann.Com 61 (Del.-Trib.) Has Distinguished The Said Case Law As Under:

Section 10(37)Section 142(1)Section 143Section 143(1)(a)Section 143(2)Section 143(3)Section 263Section 28Section 56(2)(viii)Section 57

…IN THE INCOME TAX APPELLATE TRIBUNAL, DELHI BENCH: ‘F’ NEW DELHI BEFORE SHRI SATBEER SINGH GODARA, JUDICIAL MEMBER AND SHRI M. BALAGANESH, ACCOUNTANT MEMBER Assessment Year: 2018-19 Dharmbati, Vs. Income Tax Inspector, H. No. 523, Chandawali, Faridabad Ballabhgarh, Faridabad PAN: AZIPB6400G (Appellant) (Respondent) Assessee by None Department by Ms. Monika Singh, CIT(DR) Date of hearing 05.03.2026 Date of pronouncement 05.03.2026 ORDER PER SATBEER SINGH GODARA, JM This assessee’s appeal for assessment year 2018-19, arises against the Commissioner of Income Tax (Appeals)/National Faceless Appeal Centre [in short,…

PARVEEN KUMAR,229,VILLAGE MANAKPUR-II,TEHSIL JAGADHRI,HARYANA vs. PRABHJOT KAUR,PCIT PANCHKULA, CHANDIGARH

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

ITA 576/CHANDI/2024[2018-2019]Status: DisposedITAT Chandigarh11 Feb 2026AY 2018-2019

Bench: the Tribunal as pointed out by the Registry. Considering that the issue involved is purely legal in nature, and respectfully following the ratio laid down by the Hon'ble Supreme Court in Collector, Land Acquisition v. Mst. Katiji & Others [(1987) 167 ITR 471 (SC)], which emphasizes that substantial justice should prevail over technical considerations, we condone the delay in filing these appeals.3. We shall take appeal of the assessee in ITA No. 167/Chd/2023 for A.Y 2018-19 as a lead case f

For Appellant: Shri Parikshit Aggarwal, C.A (Virtual)For Respondent: Shri Manav Bansal, CIT, DR

…ely based on the audit objection by the Audit Wing of the Department, the order of Pr. CIT was not valid. In this regard, reference is made to the following decisions:  Ajay Grover vs. Pr. CIT, Faridabad (4113/Del/2016)  CIT vs. Suhana Woolen Mills (2008) (296 ITR 238) (P & H)  Surinder Pal Singh vs. Pr. CIT (2022) (94 ITR 458)  M/s Grasim Industries vs. PCIT, Central-1, Mumbai (1964/Mum/2019) (Mumbai ITAT)  In view of the above, since the Ld. PCIT has initiated revision proceedings u/s 263 of the Act based on audit objection, the order u/s 263 is not valid and, hence, it is prayed that the impugned order u…

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CIT v. Sohana Woollen Mills (296 ITR 238) — Cited in 180 Judgments | BharatTax