CIT v. Sunbeam Auto Ltd.

332 ITR 167High Court2011#54 most cited

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.

897

judgments rely on this decision, according to BharatTax’s citation analysis of 367,368 Indian tax judgments — from 2011 to 2026.

Also referred to as

CIT v. Sunbeam Auto Ltd. · Sunbeam Auto Ltd. · Section 263 · Commissioner revisionary powers · lack of enquiry · inadequate enquiry · plausible view AO · not prejudicial to revenue · assessment order detail · different opinion Commissioner · 143(3) scrutiny assessment

Also reported as

189 Taxmann 436227 CTR 13331 DTR 189 Taxmann.com 191

Issues it is cited on

Judgments citing CIT v. Sunbeam Auto Ltd.

Satender Kumar, Sarita Vihar vs. Income Tax Officer, Civic Centre

In the result, appeal of the assessee is allowed

ITA 229/DEL/2026[2020-21]Status: DisposedITAT Delhi10 Feb 2026AY 2020-21

Bench: Sh. Satbeer Singh Godaraita No. 229/Del/2026 : Asstt. Year: 2020-21 Satender Kumar, Vs Income Tax Officer, 56, Ali Village, Sarita Vihar, Ward-28(1), New Delhi-110076 New Delhi-110001 (Appellant) (Respondent) Pan No. Afxpk4995C Assessee By: None Revenue By : Sh. Manoj Kumar, Sr. Dr Date Of Hearing: 10.02.2026 Date Of Pronouncement: 10.02.2026 Order This Assessee’S Appeal For Assessment Year 2020-21 Arises Against The Cit(A)/Nfac, Delhi’S Din & Order No. Itba/Nfac/S/250/2025-26/1082434098(1) Dated 10.11.2025, In Proceedings U/S 147 R.W.S. 144 Of The Income Tax Act, 1961 (In Short “The Act”).

For Appellant: NoneFor Respondent: Sh. Manoj Kumar, Sr. DR
Section 10(37)Section 142(1)Section 143Section 143(1)(a)Section 143(2)Section 143(3)Section 147Section 263Section 28Section 56(2)(viii)

…ely because in his order the Ld. AO did not make elaborate discussion but was satisfied with the explanation of the assessee, the order could not be held to be erroneous. In support the decisions of Hon'ble Delhi High Court in CIT vs. Sunbeam Auto Ltd. (2011) 332 ITR 167 (Del) and decision of Hon'ble Rajasthan High Court in CIT vs. Ganpat Ram Bisnoi 296 ITR 292 (Raj.) were cited. 6.2 The Ld. AR invited our attention to Audit Memo at pages 399-402 of Paper Book in the case of the assessee wherein ITO (Audit) Hisar raised an audit objection observing that interest under section 28 of Land Acquisition Act of Rs. 3,9…

Braham Dutt Vashist, Gurgaon vs. ITO-Ward -1(3), Gurgaon

In the result, appeal of the assessee is allowed

ITA 170/DEL/2026[2014-15]Status: DisposedITAT Delhi10 Feb 2026AY 2014-15

Bench: Sh. Satbeer Singh Godaraita No. 170/Del/2026 : Asstt. Year: 2014-15 Braham Dutt Vashist, Vs Income Tax Officer, C/O Ca M. R. Sahu, Ward-1(3), H. No. 651, 1St Floor, Sector-10A, Gurgaon-122001 Near G. D. Goenka Public School, Gurgaon-122001 (Appellant) (Respondent) Pan No. Affpv0127D Assessee By: Sh. M. R. Sahu, Ca Revenue By : Sh. Manoj Kumar, Sr. Dr Date Of Hearing: 10.02.2026 Date Of Pronouncement: 10.02.2026 Order This Assessee’S Appeal For Assessment Year 2014-15 Arises Against The Cit(A)/Nfac, Delhi’S Din & Order No. Itba/Nfac/S/250/2025-26/1083989454(1) Dated 23.12.2025, In Proceedings U/S 147 Of The Income Tax Act, 1961 (In Short “The Act”).

For Appellant: Sh. M. R. Sahu, CAFor Respondent: Sh. Manoj Kumar, Sr. DR
Section 10(37)Section 142(1)Section 143Section 143(1)(a)Section 143(2)Section 143(3)Section 147Section 263Section 28Section 56(2)(viii)

…ely because in his order the Ld. AO did not make elaborate discussion but was satisfied with the explanation of the assessee, the order could not be held to be erroneous. In support the decisions of Hon'ble Delhi High Court in CIT vs. Sunbeam Auto Ltd. (2011) 332 ITR 167 (Del) and decision of Hon'ble Rajasthan High Court in CIT vs. Ganpat Ram Bisnoi 296 ITR 292 (Raj.) were cited. 6.2 The Ld. AR invited our attention to Audit Memo at pages 399-402 of Paper Book in the case of the assessee wherein ITO (Audit) Hisar raised an audit objection observing that interest under section 28 of Land Acquisition Act of Rs. 3,9…

Ramavtar, Rewari vs. ITO, Rewari

In the result, appeal of the assessee is allowed

ITA 140/DEL/2026[2020-21]Status: DisposedITAT Delhi10 Feb 2026AY 2020-21

Bench: Sh. Satbeer Singh Godaraita No. 140/Del/2026 : Asstt. Year: 2020-21 Ramavtar, Vs Income Tax Officer, C/O Anu Jain & Company, Ward-1(3), 272-R, First Floor, Near Palika Near Hindu High School, Complex, Model Town, Rewari, Model Town, Rewari, Haryana-123401 Haryana-123401 (Appellant) (Respondent) Pan No. Apdpa0001R Assessee By: None Revenue By : Sh. Manoj Kumar, Sr. Dr Date Of Hearing: 10.02.2026 Date Of Pronouncement: 10.02.2026 Order This Assessee’S Appeal For Assessment Year 2020-21 Arises Against The Cit(A)/Nfac, Delhi’S Din & Order No. Itba/Nfac/S/250/2025-26/1083470019(1) Dated 09.12.2025, In Proceedings U/S 147 R.W.S. 144 Of The Income Tax Act, 1961 (In Short “The Act”).

For Appellant: NoneFor Respondent: Sh. Manoj Kumar, Sr. DR
Section 10(37)Section 142(1)Section 143Section 143(1)(a)Section 143(2)Section 143(3)Section 147Section 263Section 28Section 56(2)(viii)

…ely because in his order the Ld. AO did not make elaborate discussion but was satisfied with the explanation of the assessee, the order could not be held to be erroneous. In support the decisions of Hon'ble Delhi High Court in CIT vs. Sunbeam Auto Ltd. (2011) 332 ITR 167 (Del) and decision of Hon'ble Rajasthan High Court in CIT vs. Ganpat Ram Bisnoi 296 ITR 292 (Raj.) were cited. 6.2 The Ld. AR invited our attention to Audit Memo at pages 399-402 of Paper Book in the case of the assessee wherein ITO (Audit) Hisar raised an audit objection observing that interest under section 28 of Land Acquisition Act of Rs. 3,9…