What is CIT v. Sunbeam Auto Ltd. authority for?

The Commissioner cannot revise an assessment under Section 263 merely because the assessment order does not explicitly reflect an inquiry, or because the Commissioner holds a different opinion. An inquiry, even if considered inadequate, or an assessment based on a plausible view by the Assessing Officer after due examination, does not automatically make the order erroneous or prejudicial to the interests of the revenue.

How many judgments cite CIT v. Sunbeam Auto Ltd.?

897 judgments on BharatTax cite CIT v. Sunbeam Auto Ltd. (332 ITR 167), spanning 2011 to 2026.

Which sections of the Income Tax Act does CIT v. Sunbeam Auto Ltd. come up under?

It is most often cited in judgments turning on Section 263, Section 143(3), Section 142(1), Section 57(iv), Section 56(2)(viii), Section 10(37).

CIT v. Sunbeam Auto Ltd. (332 ITR 167)

M/S Good Earth Fertilizers Company P Ltd [Chemikas Speciality LLP], Chennai vs. ITO, Corporate Ward - 2[2], Chennai

In the result, appeal filed by the assessee is allowed

ITA 424/CHNY/2022[2017-18]Status: DisposedITAT Chennai24 Feb 2023AY 2017-18

Bench: Shri Mahavir Singh, Hon’Ble & Shri Manjunatha.G, Hon’Bleआयकरअपीलसं./Ita No.424/Chny/2022 िनधा"रणवष"/Assessment Year: 2017-18 V. M/S.Good Earth Fertilizers- The Income Tax Officer, Co. P. Ltd., Corporate Ward-2(2), (Now Known As Chemikas Chennai. Specialty Llp), No.2, North Crescent Road, T. Nagar,Chennai-600 017. [Pan:Aasfg 6012 G] (अपीलाथ"/Appellant) (""यथ"/Respondent)

For Appellant: Mr.S.Sridhar, AdvFor Respondent: Mr.R.Mohan Reddy, CIT

Section 143(3)Section 263

…आयकर अपीलीय अिधकरण, ‘ए’ "यायपीठ, चे"ई। IN THE INCOME TAX APPELLATE TRIBUNAL ‘A’ BENCH: CHENNAI "ी महावीर िसंह, माननीय उपा"", एवं "ी मंजूनाथा .जी, , माननीय लेखा सद" के सम" BEFORE SHRI MAHAVIR SINGH, HON’BLE VICE PRESIDENT AND SHRI MANJUNATHA.G, HON’BLE ACCOUNTANT MEMBER आयकरअपीलसं./ITA No.424/Chny/2022 िनधा"रणवष"/Assessment Year: 2017-18 v. M/s.Good Earth Fertilizers- The Income Tax Officer, Co. P. Ltd., Corporate Ward-2(2), (Now known as Chemikas Chennai. Specialty LLP), No.2, North Crescent Road, T. Nagar,Chennai-600 017. [PAN:AASFG 6012 G] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/ Appellant by…

Corus Vitrified Pvt. Ltd., Morbi vs. The Principal Commissioner of Income Tax - 1, Rajkot

In the result, the appeal of the assessee is allowed

ITA 119/RJT/2022[2017-18]Status: DisposedITAT Rajkot24 Feb 2023AY 2017-18

Bench: Shri Waseem Ahmed (Accountant Member), Shri Siddhartha Nautiyal (Judicial Member)

For Appellant: Shri Vimal Desai, A.RFor Respondent: Shri Shramdeep Sinha, Sr. D.R

Section 115BSection 143(3)Section 263Section 68Section 69C

…IN THE INCOME TAX APPELLATE TRIBUNAL RAJKOT BENCH, RAJKOT [CONDUCTED THROUGH VIRTUAL COURT] Before: Shri Waseem Ahmed, Accountant Member And Shri Siddhartha Nautiyal, Judicial Member Assessment Year 2017-18 Corus Vitrified Pvt. Ltd., Principal Commissioner Morbi of Income Tax-1, PAN: AAECC3548E Vs Rajkot (Appellant) (Respondent) Assessee by: Shri Vimal Desai, A.R. Revenue by: Shri Shramdeep Sinha, Sr. D.R. Date of hearing : 31-01-2023 Date of pronouncement : 24-02-2023 आदेश/ORDER PER : SIDDHARTHA NAUTIYAL, JUDICIAL MEMBER:- This assessee’s appeal for A.Y. 2017-18, arises from order of the Principal…

Shri Mukesh Chand Mal Pitti, Gandhidham-Kutch vs. The Pr. CIT-1, Rajkot

In the result, the appeal of the assessee is allowed

ITA 124/RJT/2022[2017-18]Status: HeardITAT Rajkot21 Feb 2023AY 2017-18

Bench: The Hearing Of Appeal. Total Tax Effect (See Note Below)

For Appellant: Shri R.K. Doshi, A.RFor Respondent: Shri Shramdeep Sinha, CIT-D.R

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

…IN THE INCOME TAX APPELLATE TRIBUNAL RAJKOT BENCH, RAJKOT [CONDUCTED THROUGH VIRTUAL COURT ] Before: Shri Waseem Ahmed, Accountant Member And Shri Siddhartha Nautiyal, Judicial Member Assessment Year 2017-18 Mukesh Chand Mal Pitti, Pr. CIT, Office No. S/6, 2nd Floor Rajkot-1 Ratnkala Arcade, Plot No. Vs (Respondent) 231, Ward No. 12B, Gandhidham-370201 PAN: AESPP9402K (Appellant) Assessee by: Shri R.K. Doshi, A.R. Revenue by: Shri Shramdeep Sinha, CIT-D.R. Date of hearing : 06-02-2023 Date of pronouncement : 22-02-2023 आदेश/ORDER PER : SIDDHARTHA NAUTIYAL, JUDICIAL MEMBER:- This assessee’s appeal…

Shri Tulshibhai Polabhai Sakariya, Rajkot vs. The Pr. CIT-1, Rajkot

In the result, appeal filed by assessee is allowed

ITA 93/RJT/2021[2015-16]Status: DisposedITAT Rajkot15 Feb 2023AY 2015-16

Bench: Shri Waseem Ahmed & Ms. Madhumita Royआयकरअपीलसं./Ita No. 93/Rjt/2021 िनधा"रणवष" िनधा"रणवष"/Asstt. Year:2015-16 िनधा"रणवष" िनधा"रणवष" Shri Tulsibhai Polabhai Sakariya Vs. The Pr. C.I.T, 2-Bombay Housing Society, Rajkot-1, Meghdhara, University Road, Rajkot. Opp. G. K. Dholakiya, Rajkot

For Appellant: Shri Mehul Ranpura, A.RFor Respondent: Shri Shramdeep Sinha, CIT DR

Section 143(3)Section 263Section 54F

…by invoking revisionary powers under section 263 of the Act cannot impose his own understanding to the extent of inquiry. There are a number of judgments by various Hon’ble High Courts in this regard. 14. Delhi High Court in the case of CIT Vs. Sunbeam Auto 332 ITR 167 (Del.), made a distinction between lack of inquiry and inadequate inquiry. The Hon’ble court held that where the AO has made inquiry prior to the completion of assessment, the same cannot be set aside u/s 263 of the Act on the ground of inadequate inquiry. The relevant observation of Hon’ble Delhi High Court reads as under: “15. Thus, even the Co…

Shri Rajkot District Cooperative Bank Ltd., Rajkot-Gujarat vs. The Pr. Commr. of Income Tax-1, Rajkot-Gujarat

In the result, appeal of the assessee is dismissed

ITA 123/RJT/2016[2011-12]Status: DisposedITAT Rajkot15 Feb 2023AY 2011-12

Bench: Smt.Annapurna Gupta & Shri T.R. Senthil Kumarassessment Year :2011-12 Shri Rajkot District Cooperative Vs. Pr.Cit, Rajkot-1 Bank Ltd. Rajkot. ‘Jilla Bank Bhavan’, Kasturba Road Opp: Chaudhari High School Rajkot. Pan : Aaaar 0564 K 0 अपीलाथ"/ (Appellant) "" यथ"/(Respondent) Assesseeby : Shri S.N. Soparkar, Ld.Ar Revenue By : Shri Shramdeep Sinha, Ld.Cit-Dr सुनवाई क" तार"ख/Date Of Hearing : 17/11/2022 घोषणा क" तार"ख /Date Of Pronouncement: 15/02/2023

For Appellant: Shri S.N. Soparkar, ld.ARFor Respondent: Shri Shramdeep Sinha, ld.CIT-DR

Section 143(3)Section 263Section 36

…phasis was laid by the learned counsel for the petitioner that there is difference in between a case where an inquiry has been conducted and a case where inadequate inquiry had been conducted. Reliance has been placed by him on CIT v. Sunbean Auto Ltd. [2011] 332 ITR 167/[2010] 189 Taxman 436 (Delhi) wherein a distinction has been pointed out by Delhi High Court between lack of inquiry and inadequate inquiry. It was pointed out that the aforesaid decisions had been relied upon by Delhi High Court in subsequent decision in ITO v. D.G. Housing Project Ltd. [2013] 212 Taxman 132/[2012] 20 taxmann.com 587 (Delhi). 10…

Saif Partners India IV Limited, Delhi vs. ACIT Int. Taxation-3(1)(2), Delhi

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

ITA 1138/DEL/2022[2017-18]Status: DisposedITAT Delhi13 Feb 2023AY 2017-18

Bench: Shri N.K. Billaiya & Shri Anubhav Sharma

For Appellant: Shri Kanchun Kaushal, FCAFor Respondent: Ms. Meenakshi Singh – CIT-DR

Section 10(34)Section 10(38)Section 142Section 142(1)Section 143(2)Section 143(3)Section 263

…t of the Assessing Officer to disclose his satisfaction in the Assessment Order passed thereon. Thus, this objection on the part of the Revenue cannot be accepted.” 21. We find that the Hon'ble Delhi High Court in the case of CIT Vs Sunbeam Auto reported in 332 ITR 167 has held as held as under: “We have considered the rival submissions of the counsel on the other side and have gone through the records. The first issue that arises for our consideration is about the exercise of power by the CIT under s. 263 of the IT Act. As noted above, the submission of learned counsel for the Revenue was that while passing t…

Navinchandra K. Patel, Surat vs. Principle Commissioner of Income Tax -1, Surat

In the result, appeal filed by the assessee is allowed

ITA 57/SRT/2021[2015-16]Status: DisposedITAT Surat10 Feb 2023AY 2015-16

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकर अपील सं./Ita No.57/Srt/2021 Assessment Year: (2015-16) (Physical Court Hearing) Navinchandra K. Patel, Vs. The Pcit-1, Surat. 5, Kaaliytawadi Faliya, At Post Saniya Hemad, Surat-395006. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Birpp6292D (Appellant) (Respondent) Assessee By Shri Sapnesh Sheth, Ca Respondent By Shri Ritesh Mishra, Cit(Dr) Date Of Hearing 02/02/2023 10/02/2023 Date Of Pronouncement आदेश / O R D E R Per Dr. A. L. Saini, Am: Captioned Appeal Filed By Assessee, Pertaining To Assessment Year (Ay) 2015-16, Is Directed Against The Order Passed By The Learned Principal Commissioner Of Income Tax, Surat (In Short “Ld. Pcit”], Under Section 263 Of The Income Tax Act, 1961 (Hereinafter Referred To As “The Act”), Dated 31.03.2021. 2. The Grounds Of Appeal Raised By The Assessee Are As Follows: “1. On The Facts & Circumstances Of The Case As Well As Law On The Subject, The Learned Pr. Commissioner Of Income-Tax Has Erred In Passing Revisionary Order U/S 263 Of The I.T. Act Setting Aside The Order Of Ld. Assessing Officer Passed U/S 143(3) Of The Act Dated 24.11.2017 For The Year Under Consideration Although Said Order Is Neither Erroneous Nor Prejudicial To The Interest Of Revenue. 2. On The Facts & Circumstances Of The Case As Well As Law On The Subject, The Learned Pr. Commissioner Of Income-Tax Has Erred In Observing That Order Passed By Assessing Officer U/S 143(3) Of The Act Is Erroneous On The Ground That Indexed Cost Of Acquisition Of Property Is Under Assessed By Rs.2,12,58,035/-. 3. On The Facts & Circumstances Of The Case As Well As Law On The Subject, The Learned Pr. Commissioner Of Income-Tax Has Erred In Observing That Order

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

…ment of the Hon’ble Supreme Court in the case of M/s. Malabar Industrial Co. Ltd. Vs CIT (2000) 243 ITR 83 (SC). ITA.57/SRT/2021/AY.2015-15 Navinchandra K. Patel 17. Further, we note that the Hon'ble Delhi High Court in the case of CIT Vs. Sunbeam Auto Ltd. (227 CTR 133) drew the thin line of difference between "lack of inquiry" and "inadequate inquiry" and held that in the case of inadequate inquiry there cannot be 263 order. Therefore, without prejudice, even it is held that the AO had made inadequate inquiry then also powers under section 263 of the Act cannot be invoked under the facts and circumstances of t…

Shri Nitin Bothra, Indore vs. He PCIT -1 Indore, Indore

ITA 108/IND/2022[2017-18]Status: DisposedITAT Indore09 Feb 2023AY 2017-18

Bench: Shri Chandra Mohan Garg & Shri B.M. Biyaniassessment Year: 2017-18 Shri Nitin Bothra Pr. Cit-1 बनाम/ Indore Indore Vs. (Appellant / Assessee) (Respondent / Revenue) Pan: Abqpb0064J Assessee By Shri Anil Kamal Garg, Ar Revenue By Shri P.K. Mishra, Cit-Dr Date Of Hearing 18.11.2022 Date Of Pronouncement 09.02.2023

Section 115BSection 143(3)Section 263Section 68

…by invoking revisionary powers under section 263 of the Act cannot impose his own understanding of the extent of inquiry. There were a number of judgments by various Hon’ble High Courts in this regard. 7.2 Delhi High Court in the case of CIT Vs. Sunbeam Auto 332 ITR 167 (Del.), made a distinction between lack of inquiry and inadequate inquiry. The Hon’ble court held that where the AO has made inquiry prior to the completion of assessment, the same cannot be set aside u/s 263 of the Act on the ground of inadequate inquiry. The relevant observation of Hon’ble Delhi High Court reads as under: Page 11 of 17 Shri N…

Subhash Chand Dhingra, Gurgaon vs. ACIT Central Circle-3(1), Gurgaon

The appeals are dismissed

ITA 1063/DEL/2022[2017-18]Status: DisposedITAT Delhi07 Feb 2023AY 2017-18

Bench: Shri Shamim Yahya & Shri Anubhav Sharmasubhash Chand Dhingra, Vs. Acit, House No. 1/43, Shivaji Nagar, Central Circle-3(1), Gurgaon Gurgaon (Appellant) (Respondent) Pan: Aarpd8652J Satish Kumar Dhingra, Vs. Acit, House No. 1/43, Shivaji Nagar, Circle-4(1), Gurgaon Gurgaon (Appellant) (Respondent) Pan: Aanpd1971A Ashok Kumar Dhingra, Vs. Acit, House No. 1/43, Shivaji Nagar, Circle-1(1), Gurgaon Gurgaon (Appellant) (Respondent) Pan: Abupd6730B Giriraj Dhingra, Vs. Acit, House No. 1/43, Shivaji Nagar, Circle-1(1), Gurgaon Gurgaon (Appellant) (Respondent) Pan: Achpd9434E

For Appellant: Smt. Kavita Jha, AdvFor Respondent: Sh. P. Praveen Sidharth, CIT DR

Section 10(37)Section 139(4)Section 139(5)Section 143Section 143(3)Section 145ASection 263Section 56(2)(viii)Section 57

…R 108 (Bom)]. 18. It was further submitted that the ld Pr. CIT cannot substitute his opinion in place of that of the AO to invoke his exceptional powers u/s 263. Reliance was also placed in this regard on the following judgments:-  CIT vs. Sunbeam Auto Ltd.: 332 ITR 167 (Del.)  CIT vs. Anil Kumar Sharma: 335 ITR 83 (Del.)  CIT vs. Ganpat Ram Bishnoi: 152 Taxman 242 (Raj.)  CIT vs. International Travel House: 344 ITR 554 (Del.)  CIT vs. Vikas Polymers: 341 ITR 537 (Del.)  Fab India Overseas vs. CIT: 244 CTR 380 (Del.)  CIT vs. Vodafone Essar : 212 Taxman 184 (Del.)  CIT vs. Arvind Jewellers 259 ITR 502 (Gu…

Ashok Kumar Dhingra, Gurgaon vs. ACIT Circle-1(1), Gurgaon

The appeals are dismissed

ITA 1061/DEL/2022[2017-18]Status: DisposedITAT Delhi07 Feb 2023AY 2017-18

Bench: Shri Shamim Yahya & Shri Anubhav Sharmasubhash Chand Dhingra, Vs. Acit, House No. 1/43, Shivaji Nagar, Central Circle-3(1), Gurgaon Gurgaon (Appellant) (Respondent) Pan: Aarpd8652J Satish Kumar Dhingra, Vs. Acit, House No. 1/43, Shivaji Nagar, Circle-4(1), Gurgaon Gurgaon (Appellant) (Respondent) Pan: Aanpd1971A Ashok Kumar Dhingra, Vs. Acit, House No. 1/43, Shivaji Nagar, Circle-1(1), Gurgaon Gurgaon (Appellant) (Respondent) Pan: Abupd6730B Giriraj Dhingra, Vs. Acit, House No. 1/43, Shivaji Nagar, Circle-1(1), Gurgaon Gurgaon (Appellant) (Respondent) Pan: Achpd9434E

For Appellant: Smt. Kavita Jha, AdvFor Respondent: Sh. P. Praveen Sidharth, CIT DR

Section 10(37)Section 139(4)Section 139(5)Section 143Section 143(3)Section 145ASection 263Section 56(2)(viii)Section 57

…R 108 (Bom)]. 18. It was further submitted that the ld Pr. CIT cannot substitute his opinion in place of that of the AO to invoke his exceptional powers u/s 263. Reliance was also placed in this regard on the following judgments:-  CIT vs. Sunbeam Auto Ltd.: 332 ITR 167 (Del.)  CIT vs. Anil Kumar Sharma: 335 ITR 83 (Del.)  CIT vs. Ganpat Ram Bishnoi: 152 Taxman 242 (Raj.)  CIT vs. International Travel House: 344 ITR 554 (Del.)  CIT vs. Vikas Polymers: 341 ITR 537 (Del.)  Fab India Overseas vs. CIT: 244 CTR 380 (Del.)  CIT vs. Vodafone Essar : 212 Taxman 184 (Del.)  CIT vs. Arvind Jewellers 259 ITR 502 (Gu…

Satish Kumar Dhingra, Haryana vs. ACIT Circle-4(1), Gurgaon

The appeals are dismissed

ITA 1060/DEL/2022[2017-18]Status: DisposedITAT Delhi07 Feb 2023AY 2017-18

Bench: Shri Shamim Yahya & Shri Anubhav Sharmasubhash Chand Dhingra, Vs. Acit, House No. 1/43, Shivaji Nagar, Central Circle-3(1), Gurgaon Gurgaon (Appellant) (Respondent) Pan: Aarpd8652J Satish Kumar Dhingra, Vs. Acit, House No. 1/43, Shivaji Nagar, Circle-4(1), Gurgaon Gurgaon (Appellant) (Respondent) Pan: Aanpd1971A Ashok Kumar Dhingra, Vs. Acit, House No. 1/43, Shivaji Nagar, Circle-1(1), Gurgaon Gurgaon (Appellant) (Respondent) Pan: Abupd6730B Giriraj Dhingra, Vs. Acit, House No. 1/43, Shivaji Nagar, Circle-1(1), Gurgaon Gurgaon (Appellant) (Respondent) Pan: Achpd9434E

For Appellant: Smt. Kavita Jha, AdvFor Respondent: Sh. P. Praveen Sidharth, CIT DR

Section 10(37)Section 139(4)Section 139(5)Section 143Section 143(3)Section 145ASection 263Section 56(2)(viii)Section 57

…R 108 (Bom)]. 18. It was further submitted that the ld Pr. CIT cannot substitute his opinion in place of that of the AO to invoke his exceptional powers u/s 263. Reliance was also placed in this regard on the following judgments:-  CIT vs. Sunbeam Auto Ltd.: 332 ITR 167 (Del.)  CIT vs. Anil Kumar Sharma: 335 ITR 83 (Del.)  CIT vs. Ganpat Ram Bishnoi: 152 Taxman 242 (Raj.)  CIT vs. International Travel House: 344 ITR 554 (Del.)  CIT vs. Vikas Polymers: 341 ITR 537 (Del.)  Fab India Overseas vs. CIT: 244 CTR 380 (Del.)  CIT vs. Vodafone Essar : 212 Taxman 184 (Del.)  CIT vs. Arvind Jewellers 259 ITR 502 (Gu…

Rakshita Patel, Delhi vs. AO Ward 49(2), Delhi

In the result the appeal of the assessee in ITA No

ITA 647/DEL/2022[2017-18]Status: DisposedITAT Delhi02 Feb 2023AY 2017-18

Bench: Shri N.K. Billaiya & Ms. Astha Chandra

For Appellant: Shri VedJain, AdvFor Respondent: Shri T.P. Kipgen, CIT- DR

Section 142(1)Section 143(3)Section 144Section 263Section 54

…t of the Assessing Officer to disclose his satisfaction in the Assessment Order passed thereon. Thus, this objection on the part of the Revenue cannot be accepted.” 16. We find that the Hon'ble Delhi High Court in the case of CIT Vs Sunbeam Auto reported in 332 ITR 167 has held as held as under: “We have considered the rival submissions of the counsel on the other side and have gone through the records. The first issue that arises for our consideration is about the exercise of power by the CIT under s. 263 of the IT Act. As noted above, the submission of learned counsel for the Revenue was that while passing t…

Shri Praful Gautambhai Kothari, Rajkot vs. The Pr. CIT-1, Rajkot

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

ITA 163/RJT/2021[2011-12]Status: DisposedITAT Rajkot31 Jan 2023AY 2011-12

Bench: Shri Waseem Ahmed & Ms. Madhumita Royआयकर अपील सं./Ita No. 163/Rjt/2021 िनधा"रण वष"/Asstt. Years: 2011-2012

For Appellant: Shri Gaurang Khakhar, A.RFor Respondent: Shri Shramdeep Sinha, CIT. D.R

Section 142(1)Section 143(3)Section 147Section 263

…by invoking revisionary powers under section 263 of the Act cannot impose his own understanding of the extent of inquiry. There were a number of judgments by various Hon’ble High Courts in this regard. 8.2 Delhi High Court in the case of CIT Vs. Sunbeam Auto 332 ITR 167 (Del.), made a distinction between lack of inquiry and inadequate inquiry. The Hon’ble court held that where the AO has made inquiry prior to the completion of assessment, the same cannot be set aside u/s 263 of the Act on the ground of A.Y. 2011-12 6 inadequate inquiry. The relevant observation of Hon’ble Delhi High Court reads as under: “12. ……

Bhartesh Jain, Jaipur vs. PCIT, Jaipur-1, Jaipur

ITA 326/JPR/2022[2017-18]Status: DisposedITAT Jaipur31 Jan 2023AY 2017-18

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Sh. Manish AgarwalFor Respondent: Sh. Ajay Malik, CIT

Section 143(3)Section 263

…ombay High Court in the case of CIT Vs. Gabrial India Ltd., reported in 203 ITR 108, has held that, “CIT cannot revise order merely because he disagrees with the conclusion arrived at by the ITO”. Further, in the case of CIT Vs. Sunbeam Auto Ltd., reported in 227 CTR 133, the Hon’ble Delhi High Court drew a distinction between “Lack of inquiry” and “inadequate enquiry” and held that, ‘in the case of inadequate enquiry, provisions under section 263 cannot be invoked.’ Kind attention of the hon’ble bench is also invited to the judgment of hon’ble ITAT Indore Bench in the case of Rakesh Khandelwal in ITA No. 204/In…

Shri Hari Kishan Goyal, Indore vs. Pr CIT-2, Indore

In the result, the grounds of appeal of the assessee are allowed

ITA 157/IND/2020[2015-16]Status: DisposedITAT Indore30 Jan 2023AY 2015-16

Bench: SHRI SIDDHARTHA NAUTIYAL, JUDICIAL MEBER, SHRI B.M. BIYANI, ACCOUNTNT MEMBER Shri Hari Kishan Goyal, Indore

For Appellant: Shri Ashish Goyal, A.RFor Respondent: Shri P.K. Mishra, CIT-D.R

Section 143(3)Section 263

…IN THE INCOME TAX APPELLATE TRIBUNAL INDORE BENCH, INDORE [CONDUCTED THROUGH VIRTUAL COURT ] BEFORE: SHRI SIDDHARTHA NAUTIYAL, JUDICIAL MEBER And SHRI B.M. BIYANI, ACCOUNTNT MEMBER Assessment Year 2015-16 Shri Hari Kishan Goyal, Pr. CIT-2, Indore Indore PAN: ADVPG8753E Vs (Respondent) (Appellant) Assessee by: Shri Ashish Goyal, A.R. Revenue by: Shri P.K. Mishra, CIT-D.R. Date of hearing : 08-12-2022 Date of pronouncement : 30-01-2023 आदेश/ORDER PER : SIDDHARTHA NAUTIYAL, JUDICIAL MEMBER:- This assessee’s appeal for A.Y. 2015-16, arises from order of the Principal Commissioner of Income Tax-2, Indo…