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)

Subhash Jaiswal Associates, Bareilly vs. PCIT Bareilly, Bareilly

ITA 100/LKW/2022[2017-18]Status: DisposedITAT Lucknow11 Dec 2025AY 2017-18

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

For Appellant: Respondent by

Section 143(3)Section 263

…n jurisdiction u/s.263 of the Act could be initiated by the Id. PCIT only for 'lack of enquiry' and not for 'inadequate enquiry'. Reliance in this regard is placed on the decision of Hon'ble Delhi High Court in the case of CIT vs. Sunbeam Auto Ltd reported in 332 ITR 167. In the instant case, the Id. PCIT is only trying to conclude that the ld. AO had made inadequate enquiries. The law is further settled by the recent decision of the Hon'ble Gujarat High court in the case of PCIT vs. Shree Gayatri Associates reported in 106 taxmann.com 30 (Guj) wherein it was held as under:- "3. We have heard learned counsel for…

Vaksons Metaplast Pvt Ltd, Delhi vs. PCIT(Central), Delhi

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

ITA 2218/DEL/2025[2019-20]Status: DisposedITAT Delhi05 Dec 2025AY 2019-20

Bench: Shris.Rifaur Rahman & Shri Anubhav Sharma

For Appellant: Smt. Rano Jain, AdvocateFor Respondent: Shri Amit Jain, CIT DR

Section 115BSection 132Section 139Section 143Section 153Section 153CSection 234ASection 263Section 69C

…263 of the Act. Reliance is once again placed ob: (i) Malabar Industrial Co. Ltd. v, CIT reported in [2000J 243 ITR 83 (SC) (ii) CIT (Central), Ludhiana v, Max India Ltd. reported in [2008J 166 Taxman 188 (SC) (iii) CIT v. Sunbeam Auto Ltd. reported in [2011J 332 ITR 167 (Delhi) (iv) DIT v. Jyoti Foundation reported in [2013J 357 ITR 388 (Delhi) When the AO during the course of original assessment proceedings made extensive inquiries and was satisfied with the correctness of the claim of the assessee, on the basis of which he made addition of commission income, then the order passed by the AO cannot be held as er…

Vaksons Metaplast Pvt Ltd, Delhi vs. PCIT(Central), Delhi

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

ITA 2217/DEL/2025[2018-19]Status: DisposedITAT Delhi05 Dec 2025AY 2018-19

Bench: Shris.Rifaur Rahman & Shri Anubhav Sharma

For Appellant: Smt. Rano Jain, AdvocateFor Respondent: Shri Amit Jain, CIT DR

Section 115BSection 132Section 139Section 143Section 153Section 153CSection 234ASection 263Section 69C

…263 of the Act. Reliance is once again placed ob: (i) Malabar Industrial Co. Ltd. v, CIT reported in [2000J 243 ITR 83 (SC) (ii) CIT (Central), Ludhiana v, Max India Ltd. reported in [2008J 166 Taxman 188 (SC) (iii) CIT v. Sunbeam Auto Ltd. reported in [2011J 332 ITR 167 (Delhi) (iv) DIT v. Jyoti Foundation reported in [2013J 357 ITR 388 (Delhi) When the AO during the course of original assessment proceedings made extensive inquiries and was satisfied with the correctness of the claim of the assessee, on the basis of which he made addition of commission income, then the order passed by the AO cannot be held as er…

Vaksons Metaplast Pvt Ltd, Delhi vs. PCIT(Central), Delhi

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

ITA 2216/DEL/2025[2017-18]Status: DisposedITAT Delhi05 Dec 2025AY 2017-18

Bench: Shris.Rifaur Rahman & Shri Anubhav Sharma

For Appellant: Smt. Rano Jain, AdvocateFor Respondent: Shri Amit Jain, CIT DR

Section 115BSection 132Section 139Section 143Section 153Section 153CSection 234ASection 263Section 69C

…263 of the Act. Reliance is once again placed ob: (i) Malabar Industrial Co. Ltd. v, CIT reported in [2000J 243 ITR 83 (SC) (ii) CIT (Central), Ludhiana v, Max India Ltd. reported in [2008J 166 Taxman 188 (SC) (iii) CIT v. Sunbeam Auto Ltd. reported in [2011J 332 ITR 167 (Delhi) (iv) DIT v. Jyoti Foundation reported in [2013J 357 ITR 388 (Delhi) When the AO during the course of original assessment proceedings made extensive inquiries and was satisfied with the correctness of the claim of the assessee, on the basis of which he made addition of commission income, then the order passed by the AO cannot be held as er…

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)

…in 'ULTRATECH CEMENT LTD. AND ORS. VS. STATE OF RAJASTHAN AND ORS.', CIVIL APPEAL NO.2773/2020 DECIDED ON 17.07.2020. 8. In the backdrop of aforesaid well settled legal principles, we may examine the facts of the case in hand. In 'CIT VS. SUNBEAM AUTO LTD.', 332 ITR 167, it has been held by Delhi High Court that Assessing Officer in the order of assessment is not required to give detailed reasoning in respect of each and every item of deduction and therefore, the question whether there has been an application of mind before allowing expenditure has to be examined from the record of the case. The question of lack…

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)

…in 'ULTRATECH CEMENT LTD. AND ORS. VS. STATE OF RAJASTHAN AND ORS.', CIVIL APPEAL NO.2773/2020 DECIDED ON 17.07.2020. 8. In the backdrop of aforesaid well settled legal principles, we may examine the facts of the case in hand. In 'CIT VS. SUNBEAM AUTO LTD.', 332 ITR 167, it has been held by Delhi High Court that Assessing Officer in the order of assessment is not required to give detailed reasoning in respect of each and every item of deduction and therefore, the question whether there has been an application of mind before allowing expenditure has to be examined from the record of the case. The question of lack…

International Flavours & Fragrances India Private Limited, Chennai vs. Principal Commissioner of Income Tax, Chennai

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

ITA 268/CHNY/2025[2017-18]Status: DisposedITAT Chennai02 Dec 2025AY 2017-18

For Appellant: Shri. Percy Pardiwalla, Senior AdvocateFor Respondent: Shri. Bipin C.N., C.I.T

Section 143(1)Section 143(2)Section 143(3)Section 147Section 263Section 801B

…If not, he has no authority to initiate proceedings for revision. Exercise of power of suo moto revision under such circumstances will amount to arbitrary exercise power.” 20. Additionally, reliance is also placed in the case of CIT vs Sunbeam Auto Ltd [2011] 332 ITR 167 (Del) wherein the Hon'ble High Court of Delhi held that (refer para 12 in page no. 58 of the case law paper book on jurisdictional grounds) 21. 12. “One has to keep in mind the distinction between lack of inquiry and inadequate inquiry. If there was any inquiry, even inadequate, that would not by itself, give occasion to the Commissioner to pass…

Mawasi, Haryana vs. Commissioner of Income Tax (Appeals), Delhi

In the result, appeal of the assessee is allowed

ITA 5020/DEL/2025[2017-18]Status: DisposedITAT Delhi02 Dec 2025AY 2017-18

Bench: Sh. Satbeer Singh Godara & Sh. Manish Agarwal

For Appellant: NoneFor Respondent: Ms. Amisha S. Gupta, CIT-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…

Raj Singh, Delhi vs. Commissioner of Income Tax (Appeals), National Faceless Appeal Centre Delhi

In the result, appeal of the assessee is allowed

ITA 6710/DEL/2025[2020-2021]Status: DisposedITAT Delhi28 Nov 2025AY 2020-2021

Bench: Shri Satbeer Singh Godaraassessment Year: 2020-21

Section 10(37)Section 142(1)Section 143Section 143(1)(a)Section 143(3)Section 147Section 2Section 263Section 28Section 3

…1 IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH ‘SMC’ NEW DELHI BEFORE SHRI SATBEER SINGH GODARA, JUDICIAL MEMBER Assessment Year: 2020-21 Raj Singh, Vs Assessing Officer, H. No. 258-A, S/o Kehar Singh, Assessment Unit, Village Basai, Tehsil Gurg near Income Tax Department Flyover, Gurgaon-122001. PAN: CSLPS 0693 C APPELLANT RESPONDENT Assessee represented by Shri Mukesh Pandey, AR Department represented by Shri Manoj Kumar, Sr. DR Date of hearing 27.11.2025 Date of pronouncement 27.11.2025 O R D E R PER SATBEER SINGH GODARA, JM: This assessee’s appeal ITA no. 6710/Del/ /2025 for assessment year 2020-21 ar…

Rajpal, Jhajjar vs. Income Tax Officer, National Faceless Assessment Unit

In the result, appeal of the assessee is allowed

ITA 6697/DEL/2025[2020-2021]Status: DisposedITAT Delhi28 Nov 2025AY 2020-2021

Bench: Shri Satbeer Singh Godaraassessment Year: 2020-21

Section 10(37)Section 142(1)Section 143Section 143(1)(a)Section 143(3)Section 147Section 263Section 28Section 3Section 56(2)(viii)

…1 IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH ‘SMC’ NEW DELHI BEFORE SHRI SATBEER SINGH GODARA, JUDICIAL MEMBER Assessment Year: 2020-21 Rajpal Vs Assessing Officer, S/o Hari Singh village post office Assessment Unit, Goria, MAT Anhail Jhajjar-124142 Income Tax Department PAN: AVOPR 2101 A APPELLANT RESPONDENT Assessee represented by Shri Rajpal (Individual) Department represented by Shri Manoj Kumar, Sr. DR Date of hearing 27.11.2025 Date of pronouncement 27.11.2025 O R D E R PER SATBEER SINGH GODARA, JM: This assessee’s appeal ITA no. 6697/Del/ /2025 for assessment year 2020-21 arises against CIT(A)/…

Tara Vati, Gurgaon, Haryana vs. Circle 3(1) Gurgaon, Gurgaon

In the result, appeal of the assessee is allowed

ITA 6552/DEL/2025[2020-21]Status: DisposedITAT Delhi26 Nov 2025AY 2020-21

Bench: Shri Satbeer Singh Godaraassessment Year: 2020-21

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

…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,…

Charanjeet Singh, Panipat vs. Income Tax Officer, Ward 1, Panipat

In the result, appeal of the assessee is allowed

ITA 6387/DEL/2025[2018-19]Status: DisposedITAT Delhi25 Nov 2025AY 2018-19

Bench: Shri Satbeer Singh Godaraassessment Year: 2018-19 Sh. Charanjeet Singh, Vs. Income Tax Officer, H. No. 115, Baholi, Ward-1, Panipat Refinery, Panipat Panipat, Haryana Pan: Ddaps7473H (Appellant) (Respondent) Assessee By Sh. Suresh Gupta, Ca Department By Sh. Manoj Kumar, Sr. Dr

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

…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…

Vision & Vision Private Limited, Jamshedpur vs. Acut/ DCIT Circle 1, Jamshedpur

In the result, the appeal of the assessee is allowed

ITA 183/RAN/2025[2018-19]Status: DisposedITAT Ranchi19 Nov 2025AY 2018-19

Bench: Shri Sonjoy Sarma & Shri Ratnesh Nandan Sahayi.T.A. No.183/Ran/2025 Assessment Year: 2018-19 Vision & Vision Pvt. Ltd.…….……………............................……….……Appellant Block No.2, Ambika Tower, Main Road Shastri Nagar, Jamshedpur – 831005. [Pan: Aabcv5072B] Vs. Acit/Dcit, Circle-1, Jamshedpur ..…..….........……........……...…..…..Respondent Appearances By: Shri Akshay Ringasia, Ar, Ar, Appeared On Behalf Of The Appellant. Shri Kanhaiya Lal Kanak, Cit-Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : November 12, 2025 Date Of Pronouncing The Order : November 19, 2025 Order Per Sonjoy Sarma: This Appeal By The Assessee Is Directed Against The Order Of The Learned Principal Commissioner Of Income Tax (Pcit), Ranchi, Passed Under Section 263 Of The Income-Tax Act, 1961 (“The Act”) Dated 31.03.2025 For A.Y. 2018–19. The Assessee Challenges The Legality & Validity Of The Assumption Of Jurisdiction By The Pcit & The Consequent Revision Of The Reassessment Order Passed U/S 147 R.W.S. 144B Dated 27.03.2023. 2. Brief Facts Of The Case Are That The Assessee Filed Return Of Income For A.Y. 2018–19 Declaring Total Income Of ₹11,95,030. The Return Was Initially Processed U/S 143(1). Later, Based On Information Shared By The Ddit (Investigation), Kolkata, It Was Alleged That The Assessee Had Received An Accommodation Entry Of ₹1,18,61,425 From M/S Kuldeepak Enterprises During The Year. On This Basis, The Ao Reopened The

Section 142(1)Section 143(1)Section 147Section 148Section 263

…ce the AO has applied his mind and taken one of the possible views, revision is not permissible as held by Hon'ble Supreme Court as in the case of Malabar Industrial Co. Ltd. v. CIT 243 ITR 83 (SC) and Hon'ble Delhi High Court in the case of Sunbeam Auto Ltd. 332 ITR 167 (Del)). The alleged issue pertains to earlier year therefore any addition in A.Y. 2018–19 would lead to double taxation, rendering the revision order I.T.A. No.183/Ran/2025 Vision & Vision Pvt. Ltd revenue-neutral and therefore not prejudicial to the interests of the Revenue. Reliance is also placed on the judgments of CIT v. Jet Airways Ltd. (B…

Mayurbhai Jaysukhlal Shah, Jamnagar vs. Principal Commissioner of Income Tax, Jamnagar

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

ITA 319/RJT/2024[2013-14]Status: DisposedITAT Rajkot19 Nov 2025AY 2013-14

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./Ita Nos. 319/Rjt/2024 (Assessment Year: 2013-14) (Hybrid Hearing) Mayurbhai Jaysukhlal Shah Vs. Principal Commissioner Of 601, Cross Way, P.N. Marg, Income Tax, Jamnagar Jamnagar, Gujarat-361001 Office Of The Principal Commissioner Of Income Tax.Pcit, Jamnagar "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Afgps1754J (अपीलाथ"/Assessee) (""यथ"/Respondent)

For Appellant: Shri Chetan Agarwal, Ld. ARFor Respondent: Shri Sanjay Punglia, Ld. CIT(DR)

Section 10(38)Section 143Section 147Section 263Section 68

…o remit the issue to the file of assessing officer without finding that the order of assessing officer is erroneous in so far as prejudicial to the interest of revenue as held by Hon'ble Delhi High Court in the case of CIT vs. Sunbeam Auto Limited reported in 332 ITR 167 (Del). 12. From the facts of the assessee`s case we find that assessee is a regular investor in capital market and not a one-time adventurer and as such has done the investments in such shares as a pure investor only. The assessee had purchased 83,000 shares of Shree Leather Ltd, on 17.03.2010 and for the same, the payment was made of Rs. 1,25,2…

Jitendrasinh Zala, Jamnagar vs. The Pr.Commissioner of Income Tax, Jamnagar

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

ITA 871/RJT/2024[2020-21]Status: DisposedITAT Rajkot18 Nov 2025AY 2020-21

Bench: Dr. Arjun Lal Saini. & Dinesh Mohan Sinha

For Appellant: Shri Chetan Agarwal, Ld. ARFor Respondent: Shri Sanjay Punglia, Ld. CIT(DR)

Section 143(3)Section 263

…ence between ‘Lack of enquiry’ and ‘inadequate enquiry’. It is for the assessing officer to decide the extent of enquiry to be made as it is his satisfaction as what is required under law. Reliance is placed on the decision of CIT v. Sunbeam Auto Ltd. [(2010) 332 ITR 167], wherein Hon’ble Delhi High Court has held that if there was any inquiry, even inadequate, that would not by itself, give occasion to the Commissioner to pass order u/s 263 of the Act, merely because the Commissioner has a different opinion in the matter and that only in cases where there is no enquiry, the power u/s 263 of the Act can be exerci…

Ganga Bishan, Gurgaon vs. ITO Ward 1(3), Gurgaon

In the result, appeal of the assessee is allowed

ITA 2179/DEL/2025[2019-20]Status: DisposedITAT Delhi17 Nov 2025AY 2019-20

Bench: Sh. Satbeer Singh Godara & Sh. S. Rifaur Rahman

For Appellant: NoneFor Respondent: Sh. Ajay Kumar Arora, 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…

Anjani Agarwal, Kolkata vs. PCIT (Central) Kolkata - 2, Kolkata

In the result, the appeal of the assessee is allowed

ITA 403/KOL/2025[2021-22]Status: DisposedITAT Kolkata11 Nov 2025AY 2021-22

Bench: Shri Duvvuru Rl Reddy, Vp & Shri Rajesh Kumar, Am Pcit (Central) Kolkata-2, Anjani Agarwal Dcit, Central Circle-4(3), 1D, Ashoka, 14, Ashoka Road, Aayakar Bhawan Poorva, Alipore H.O. Vs. 110, Shantipally, Kolkata- Kolkata-700027, West Bengal 700107, West Bengal (Appellant) (Respondent) Pan No. Aehpa0038H Assessee By : Shri S.K. Tulsiyan, Ar Revenue By : Shri Raja Sengupta, Dr Date Of Hearing: 21.08.2025 Date Of Pronouncement: 11.11.2025

For Appellant: Shri S.K. Tulsiyan, ARFor Respondent: Shri Raja Sengupta, DR

Section 142(1)Section 143(3)Section 263Section 56(2)(x)

…] 366 ITR 593 (Calcutta) dated 15-05-2014. The ld. AR also relied on the decision of Principal Commissioner of Income-tax vs. Britannia Industries Ltd. [2023] 146 taxmann.com 246 (Calcutta)[25-08-2022], Commissioner of Income- tax vs. Sunbeam Auto Ltd. [2011] 332 ITR 167 (Delhi), PCIT Vs V. Con Integrated Solutions (P) Ltd (2025) 173 taxmann.com 773(P&H) which has been affirmed by the Hon,ble Apex Court in PCIT Vs V. Con Integrated Solutions (P) Ltd (2025) 173 taxmann.com 774(SC) by dismissing the SLP filed by the Revenue. Similarly the ld AR also relied on the decisions of Hon’ble Apex Court namely CIT Vs Max In…

Vivek Nathuram Gavhane, Pune vs. The Pr. Commissioner of Income Tax, Central, Pune

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

ITA 849/PUN/2025[2020-21]Status: DisposedITAT Pune04 Nov 2025AY 2020-21

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.849/Pun/2025 Assessment Year : 2020-21

For Appellant: Shri Nikhil S. PathakFor Respondent: Shri Amit Bobde

Section 133ASection 143(2)Section 143(3)Section 263Section 32Section 69C

…asion to the Commissioner to exercise the power of revision u/s 263 as held by the Hon’ble Bombay High Court in the case of CIT vs. Gabriel India Ltd., 203 ITR 108 (Bombay) and followed by the Hon’ble Delhi High Court in the case of CIT vs. Sunbeam Auto Ltd., 332 ITR 167 (Delhi) and in the case of CIT vs. Anil Kumar Sharma, 335 ITR 83 (Delhi). The relevant paragraphs of the decision of the Hon’ble Delhi High Court in the case of Sunbeam Auto Ltd. (supra) are extracted hereunder :- “We have considered the rival submissions of the counsel on the other side and have gone through the records. The first issue that ar…

Sanjay, Gurgaon vs. ITO, Ward 4(1)-Gurgaon, Gurgaon

In the result, appeal of the assessee is allowed

ITA 5952/DEL/2025[2016-17]Status: DisposedITAT Delhi30 Oct 2025AY 2016-17

Bench: Sh. Satbeer Singh Godaraita No. 5952/Del/2025 : Asstt. Year : 2016-17 Sanjay Vs Income Tax Officer, C/O Ca, M. R. Sahu, Ward-4(1), House No. 651, 1St Floor, Sector- Gurgaon, 10A, Near G. D. Goenka Public Haryana-122050 School, Gurgaon-122001 (Appellant) (Respondent) Pan No. Eqsps3018G Assessee By : Sh. M. R. Sahu, Ca & Sh. Sudhir Yadav, Ca Revenue By : Sh. Manoj Kumar, Sr. Dr Date Of Hearing: 30.10.2025 Date Of Pronouncement: 30.10.2025 Order

For Appellant: Sh. M. R. Sahu, CA &For 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 4 Sanjay 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 o…

Sapphire Reclaim Rubber Private Limited, Shapar, Rajkot vs. The Principal Commissioner of Income Tax -1, Rajkot

In the result, appeal filed by the Assessee is rejected

ITA 272/RJT/2024[2014-15]Status: DisposedITAT Rajkot28 Oct 2025AY 2014-15

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकरअपीलसं./Ita No. 272/Rjt/2024 ("नधा"रणवष" / Assessment Year: (2014-15) (Hybrid Hearing) Sapphire Reclaim Rubber Pvt. Ltd. Vs. The Principal Commissioner Of Bhoomi Industrial Area, Plot No: Income Tax-1, 2Nd Floor Aayakar Bhawan, Race 1/44, National Highway 27, Veraval (Shapar), Course Ring Road, Rajkot - 360311 Rajkot Gujarat - 361006 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aapcs6205B (Appellant) (Respondent) Appellant By : Shri Vimal Desai, Ld. Ar Respondent By : Shri Sanjay Punglia, Ld. Sr. (Dr) Date Of Hearing : 30/07/2025 Date Of Pronouncement : 28/10/2025

For Appellant: Shri Vimal Desai, Ld. ARFor Respondent: Shri Sanjay Punglia, Ld. Sr. (DR)

Section 115BSection 132Section 133ASection 147Section 148Section 263Section 69A

…2021)-130 taxmann.com 294: [Page No. 60-63]  Supreme Court in the case of Nirav Modi 77 taxmann.com 78: [Page No. 64-65]  Gujarat High Court in the case of Amit Corporation. taxmann.com 64. [Page No. 66-67] 21  Delhi High Court in case of Sunbeam Auto Ltd. 332 ITR 167 [Page No. 68-78]  Mumbai ITAT in case of Narayan Tatu Rane - 70 taxmann.com 227 [Page No. 79-891  Rajkot ITAT in case of Metropole Tiles Pvt Ltd. (decision dated 24.08.2022 in ITA no. 59/Rjt/2021) - [Page No. 90-114] (iv) The Supreme Court judgment in the case of Principal Commissioner of Income Tax vs. Shreeji Prints (P.) Ltd. (2021) 130 taxm…

CIT v. Sunbeam Auto Ltd.

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

Also referred to as

Also reported as

Sections most often in play

Issues it is cited on

Judgments citing CIT v. Sunbeam Auto Ltd.

Subhash Jaiswal Associates, Bareilly vs. PCIT Bareilly, Bareilly

Vaksons Metaplast Pvt Ltd, Delhi vs. PCIT(Central), Delhi

Vaksons Metaplast Pvt Ltd, Delhi vs. PCIT(Central), Delhi

Vaksons Metaplast Pvt Ltd, Delhi vs. PCIT(Central), Delhi

Bhavana Co-Op Credit Society Niyamita, Sirsi vs. Income Tax Officer, Ward-1, Sirsi

Gonikoppal Primary Rural Agricultural Credit Co-Operative Society Limited, Kodagu vs. Pr. Commissioner of Income Tax, Bengaluru-3, Bengaluru

International Flavours & Fragrances India Private Limited, Chennai vs. Principal Commissioner of Income Tax, Chennai

Mawasi, Haryana vs. Commissioner of Income Tax (Appeals), Delhi

Raj Singh, Delhi vs. Commissioner of Income Tax (Appeals), National Faceless Appeal Centre Delhi

Rajpal, Jhajjar vs. Income Tax Officer, National Faceless Assessment Unit

Tara Vati, Gurgaon, Haryana vs. Circle 3(1) Gurgaon, Gurgaon

Charanjeet Singh, Panipat vs. Income Tax Officer, Ward 1, Panipat

Vision & Vision Private Limited, Jamshedpur vs. Acut/ DCIT Circle 1, Jamshedpur

Mayurbhai Jaysukhlal Shah, Jamnagar vs. Principal Commissioner of Income Tax, Jamnagar

Jitendrasinh Zala, Jamnagar vs. The Pr.Commissioner of Income Tax, Jamnagar

Ganga Bishan, Gurgaon vs. ITO Ward 1(3), Gurgaon

Anjani Agarwal, Kolkata vs. PCIT (Central) Kolkata - 2, Kolkata

Vivek Nathuram Gavhane, Pune vs. The Pr. Commissioner of Income Tax, Central, Pune

Sanjay, Gurgaon vs. ITO, Ward 4(1)-Gurgaon, Gurgaon

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