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 367,514 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

Sections most often in play

Section 263Section 143(3)Section 142(1)Section 57(iv)Section 56(2)(viii)Section 10(37)Section 143(2)Section 147
Read the full judgment

Issues it is cited on

section 145bsection 45(5)section 145a(b)section 57(iv)inadequate enquirysection 56(2)(viii)lack of enquirysection 10(37)enhanced compensationmalabar industrialsection 263(1)section 145a

Judgments citing CIT v. Sunbeam Auto Ltd.

Kishor Veljibhai Fofandi, Veraval vs. Pr. CIT, Rajkot-1, Rajkot

ITA 326/RJT/2024[2019-20]Status: DisposedITAT Rajkot30 Jun 2025AY 2019-20

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

Section 115BSection 143(3)Section 263Section 69A

…There is difference between ‘Lack of enquiry’ and ‘inadequate enquiry’. It is for the AO 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…

Deepmala Marine Exports, Veraval vs. Pr. CIT, Rajkot-1, Rajkot

ITA 324/RJT/2024[2019-20]Status: DisposedITAT Rajkot30 Jun 2025AY 2019-20

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

Section 115BSection 143(3)Section 263Section 69A

…There is difference between ‘Lack of enquiry’ and ‘inadequate enquiry’. It is for the AO 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…

Chunilal Govind Vanik, Veraval vs. Pr. CIT, Rajkot-1, Rajkot

ITA 323/RJT/2024[2019-20]Status: DisposedITAT Rajkot30 Jun 2025AY 2019-20

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

Section 115BSection 143(3)Section 263Section 69A

…There is difference between ‘Lack of enquiry’ and ‘inadequate enquiry’. It is for the AO 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…

Bharatkumar Kalyanjibhai Bhindi, Junagadh vs. PCIT, Rajkot-1, Rajkot

ITA 312/RJT/2024[2019-20]Status: DisposedITAT Rajkot30 Jun 2025AY 2019-20

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhasr. No. 1. 2. 3. 4. 5. 6. 7. 8. 9. 10. 324/Rjt/2024 322/Rjt/2024 323/Rjt/2024 312/Rjt/2024 326/Rjt/2024 327/Rjt/2024 329/Rjt/2024 331/Rjt/2024 335/Rjt/2024 371/Rjt/2024

Section 115BSection 143(3)Section 263Section 69A

…There is difference between ‘Lack of enquiry' and 'inadequate enquiry'. It is for the AO 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…

Muhammad Zameer Qureshi, Bareilly vs. Pr. CIT, Bareilly

The appeal of the assessee stands allowed

ITA 344/LKW/2024[2014-15]Status: DisposedITAT Lucknow30 Jun 2025AY 2014-15

Bench: Shri. Sudhanshu Srivastava & Shri Nikhil Choudharyassessment Year: 2014-15 Shri Muhammad Zameer Qureshi V. The Pcit 180, Azam Nagar Bareilly Bareilly Tan/Pan:Aacpz6783H (Appellant) (Respondent) Appellant By: Shri P. K. Kapoor, C.A. Respondent By: Shri Neeraj Kumar, Cit(Dr) O R D E R

For Appellant: Shri P. K. Kapoor, C.AFor Respondent: Shri Neeraj Kumar, CIT(DR)
Section 139(4)Section 144BSection 147Section 148Section 263Section 69

…as on the lower side and left to him, he would have estimated the income at a figure higher than the one estimated by the AO. 5.1 One may, at this juncture, refer to the judgment of the Hon'ble Delhi High Court in the case of CIT vs. Sunbeam Auto Ltd. (2011) 332 ITR 167 (Del) wherein the Hon'ble Delhi High Court was considering the aspect, when there is no proper or full verification, and it was 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 Commi…

Ct. Ramanathan (HUF), Pudukkottai vs. PCIT 1, Madurai

Appeal of the assessee is allowed

ITA 761/CHNY/2025[2020-21]Status: DisposedITAT Chennai25 Jun 2025AY 2020-21

Bench: Hon’Ble Shri Manu Kumar Giri & Hon’Ble Shri S.R. Raghunathaआयकर अपील सं./Ita No.761/Chny/2025 Assessment Years: 2020-21 C.T.Ramanathan(Huf), Income Tax Officer, No.7/45, Ct.Rm.S.House, M.St.S. Street Ward-1, Kulipirai, Pudukottai Dist, Pudukottai. Tamil Nadu-622 402. [Pan: Aaahc0701L] (प्रत्यर्थी/Respondent) (अपीलार्थी/Appellant) अपीलार्थी की ओर से/ Assessee By : Mr.V.Subbarayan, Dcit(Retd.) प्रत्यर्थी की ओर से /Revenue By : Mr.M.K.Biju, Cir Dr By Virtual. सुनवाई की तारीख/Date Of Hearing : 03.06.2025 घोषणा की तारीख /Date Of Pronouncement : 25.06.2025 आदेश / O R D E R

For Appellant: Mr.V.Subbarayan, DCIT(Retd.)For Respondent: Mr.M.K.Biju, CIR DR by virtual
Section 143(3)Section 263Section 3

…on 263 would be open. In this regard, we may refer the following judicial precedents: - Kwality Steel Suppliers SC 395 ITR 1 Complex Virtusa Consulting Services HC-Madras 442 ITR 385 (P.) Ltd. Globus Infocom Ltd. HC-Delhi 369 ITR 14 Sunbeam Auto Ltd. HC-Delhi 332 ITR 167 Mohak Real Estate (P.) Ltd HC-Delhi 161 taxmann.com 388 Clix Finance India (P.) Ltd HC-Delhi 298 Taxman 217 Spectra Shares & Scrips (P) HC-Andra 354 ITR 35 Ltd. Pradesh Chemsworth (P.) Ltd. HC-Karnataka 119 taxmann.com 358 Shriram Properties Limited ITAT-Chennai 2023 (4) TMI 375 Cavinkare (P.) Ltd. ITAT-Chennai 149 taxmann.com 296 Rajkumar Impex…

ITO, Ward-1(1), Faridabad vs. Chaman, Faridabad

In the result, appeal of the assessee is allowed

ITA 2774/DEL/2024[2017-18]Status: DisposedITAT Delhi25 Jun 2025AY 2017-18

Bench: Shri Satbeer Singh Godara & Shri S. Rifaur Rahmanassessment Year: 2017-18 Vs. Chaman, Income Tax Officer, Ward-1(1), H. No. 437, Sector-9, Faridabad Faridabad Pan: Bfapd6698P (Appellant) (Respondent) With C.O. No.103/Del/2024 [Arising Out Of Ita No.2774/Del/2024] Assessment Year: 2017-18 Vs. Income Tax Officer, Chaman, H. No. 437, Sector-9, Ward-1(1), Faridabad, Haryana Faridabad Pan: Bfapd6698P (Appellant) (Respondent) Assessee By Sh. Gaurav, Adv. Department By Sh. Rajesh Kumar Dhanesta, Sr. Dr Date Of Hearing 25.06.2025 Date Of Pronouncement 25.06.2025 Order Per Satbeer Singh Godara, Jm This Revenue’S Appeal Ita No. 2774/Del/2024 & Assessee’S Cross Objection C.O. No. 103/Del/2024 For Assessment Year 2017- 18, Arises Against The Commissioner Of Income Tax (Appeals)/National Faceless Appeal Centre [In Short, The

Section 147Section 250(4)

…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 12 | P a g e ITA No.2774/Del/2024 & C.O. No. 103/Del/2024 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…

Hari Singh, Palwal vs. ITO, Ward-1(3), Faridabad

In the result, appeal of the assessee is allowed

ITA 4082/DEL/2024[2019-20]Status: DisposedITAT Delhi23 Jun 2025AY 2019-20

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

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.…

Raghav Bahl, Delhi vs. Deputy Commissioner of Income Tax, Central Circle- 1, Noida

In the result, the captioned appeals filed by the assessees are allowed

ITA 1835/DEL/2024[2018-19]Status: DisposedITAT Delhi20 Jun 2025AY 2018-19

Bench: Ms. Madhumita Roy & Shri Naveen Chandraa.Y. 2013-14 A.Y. 2014-15 A.Y. 2015-16 A.Y. 2016-17 A.Y. 2017-18 A.Y. 2019-20 A.Y. 2018-19

Section 24Section 263Section 263(1)

…n taken by the AO in the assessment order the same cannot be held to be prejudicial to the interests of Revenue. In support of his contention Ld. AR relied upon the decision of the Hon’ble Delhi High Court in the case of CIT v. Sunbeam Auto Pvt. Ltd. [2011] 332 ITR 167 (Del.), which has been duly considered by us and found to be applicable in the case in hand having regard to the facts and circumstances of the case. Thus, when the claims of the assessee have been duly examined during original assessment proceedings and also the reassessment proceedings under Section 153A of the Act itself, there could have be…

Ritu Kapur, Delhi vs. Deputy Commissioner of Income Tax, Central Circle- 1, Noida

In the result, the captioned appeals filed by the assessees are allowed

ITA 1834/DEL/2024[2019-20]Status: DisposedITAT Delhi20 Jun 2025AY 2019-20

Bench: Ms. Madhumita Roy & Shri Naveen Chandraa.Y. 2013-14 A.Y. 2014-15 A.Y. 2015-16 A.Y. 2016-17 A.Y. 2017-18 A.Y. 2019-20 A.Y. 2018-19

Section 24Section 263Section 263(1)

…n taken by the AO in the assessment order the same cannot be held to be prejudicial to the interests of Revenue. In support of his contention Ld. AR relied upon the decision of the Hon’ble Delhi High Court in the case of CIT v. Sunbeam Auto Pvt. Ltd. [2011] 332 ITR 167 (Del.), which has been duly considered by us and found to be applicable in the case in hand having regard to the facts and circumstances of the case. Thus, when the claims of the assessee have been duly examined during original assessment proceedings and also the reassessment proceedings under Section 153A of the Act itself, there could have be…

Ritu Kapur, Delhi vs. Deputy Commissioner of Income Tax, Central Circle- 1, Noida

In the result, the captioned appeals filed by the assessees are allowed

ITA 1833/DEL/2024[2018-19]Status: DisposedITAT Delhi20 Jun 2025AY 2018-19

Bench: Ms. Madhumita Roy & Shri Naveen Chandraa.Y. 2013-14 A.Y. 2014-15 A.Y. 2015-16 A.Y. 2016-17 A.Y. 2017-18 A.Y. 2019-20 A.Y. 2018-19

Section 24Section 263Section 263(1)

…n taken by the AO in the assessment order the same cannot be held to be prejudicial to the interests of Revenue. In support of his contention Ld. AR relied upon the decision of the Hon’ble Delhi High Court in the case of CIT v. Sunbeam Auto Pvt. Ltd. [2011] 332 ITR 167 (Del.), which has been duly considered by us and found to be applicable in the case in hand having regard to the facts and circumstances of the case. Thus, when the claims of the assessee have been duly examined during original assessment proceedings and also the reassessment proceedings under Section 153A of the Act itself, there could have be…

Ritu Kapur, Delhi vs. Deputy Commissioner of Income Tax, Central Circle- 1, Noida

In the result, the captioned appeals filed by the assessees are allowed

ITA 1832/DEL/2024[2017-18]Status: DisposedITAT Delhi20 Jun 2025AY 2017-18

Bench: Ms. Madhumita Roy & Shri Naveen Chandraa.Y. 2013-14 A.Y. 2014-15 A.Y. 2015-16 A.Y. 2016-17 A.Y. 2017-18 A.Y. 2019-20 A.Y. 2018-19

Section 24Section 263Section 263(1)

…n taken by the AO in the assessment order the same cannot be held to be prejudicial to the interests of Revenue. In support of his contention Ld. AR relied upon the decision of the Hon’ble Delhi High Court in the case of CIT v. Sunbeam Auto Pvt. Ltd. [2011] 332 ITR 167 (Del.), which has been duly considered by us and found to be applicable in the case in hand having regard to the facts and circumstances of the case. Thus, when the claims of the assessee have been duly examined during original assessment proceedings and also the reassessment proceedings under Section 153A of the Act itself, there could have be…

Ritu Kapur, Delhi vs. Deputy Commissioner of Income Tax, Central Circle- 1, Noida

In the result, the captioned appeals filed by the assessees are allowed

ITA 1831/DEL/2024[2016-17]Status: DisposedITAT Delhi20 Jun 2025AY 2016-17

Bench: Ms. Madhumita Roy & Shri Naveen Chandraa.Y. 2013-14 A.Y. 2014-15 A.Y. 2015-16 A.Y. 2016-17 A.Y. 2017-18 A.Y. 2019-20 A.Y. 2018-19

Section 24Section 263Section 263(1)

…n taken by the AO in the assessment order the same cannot be held to be prejudicial to the interests of Revenue. In support of his contention Ld. AR relied upon the decision of the Hon’ble Delhi High Court in the case of CIT v. Sunbeam Auto Pvt. Ltd. [2011] 332 ITR 167 (Del.), which has been duly considered by us and found to be applicable in the case in hand having regard to the facts and circumstances of the case. Thus, when the claims of the assessee have been duly examined during original assessment proceedings and also the reassessment proceedings under Section 153A of the Act itself, there could have be…

Ritu Kapur, Delhi vs. Deputy Commissioner of Income Tax, Central Circle- 1, Noida

In the result, the captioned appeals filed by the assessees are allowed

ITA 1830/DEL/2024[2015-16]Status: DisposedITAT Delhi20 Jun 2025AY 2015-16

Bench: Ms. Madhumita Roy & Shri Naveen Chandraa.Y. 2013-14 A.Y. 2014-15 A.Y. 2015-16 A.Y. 2016-17 A.Y. 2017-18 A.Y. 2019-20 A.Y. 2018-19

Section 24Section 263Section 263(1)

…n taken by the AO in the assessment order the same cannot be held to be prejudicial to the interests of Revenue. In support of his contention Ld. AR relied upon the decision of the Hon’ble Delhi High Court in the case of CIT v. Sunbeam Auto Pvt. Ltd. [2011] 332 ITR 167 (Del.), which has been duly considered by us and found to be applicable in the case in hand having regard to the facts and circumstances of the case. Thus, when the claims of the assessee have been duly examined during original assessment proceedings and also the reassessment proceedings under Section 153A of the Act itself, there could have be…

Ritu Kapur, Delhi vs. Deputy Commissioner of Income Tax, Central Circle- 1, Noida

In the result, the captioned appeals filed by the assessees are allowed

ITA 1829/DEL/2024[2014-15]Status: DisposedITAT Delhi20 Jun 2025AY 2014-15

Bench: Ms. Madhumita Roy & Shri Naveen Chandraa.Y. 2013-14 A.Y. 2014-15 A.Y. 2015-16 A.Y. 2016-17 A.Y. 2017-18 A.Y. 2019-20 A.Y. 2018-19

Section 24Section 263Section 263(1)

…n taken by the AO in the assessment order the same cannot be held to be prejudicial to the interests of Revenue. In support of his contention Ld. AR relied upon the decision of the Hon’ble Delhi High Court in the case of CIT v. Sunbeam Auto Pvt. Ltd. [2011] 332 ITR 167 (Del.), which has been duly considered by us and found to be applicable in the case in hand having regard to the facts and circumstances of the case. Thus, when the claims of the assessee have been duly examined during original assessment proceedings and also the reassessment proceedings under Section 153A of the Act itself, there could have be…

Ritu Kapur, Delhi vs. Deputy Commissioner of Income Tax, Central Circle- 1, Noida

In the result, the captioned appeals filed by the assessees are allowed

ITA 1828/DEL/2024[2013-14]Status: DisposedITAT Delhi20 Jun 2025AY 2013-14

Bench: Ms. Madhumita Roy & Shri Naveen Chandraa.Y. 2013-14 A.Y. 2014-15 A.Y. 2015-16 A.Y. 2016-17 A.Y. 2017-18 A.Y. 2019-20 A.Y. 2018-19

Section 24Section 263Section 263(1)

…n taken by the AO in the assessment order the same cannot be held to be prejudicial to the interests of Revenue. In support of his contention Ld. AR relied upon the decision of the Hon’ble Delhi High Court in the case of CIT v. Sunbeam Auto Pvt. Ltd. [2011] 332 ITR 167 (Del.), which has been duly considered by us and found to be applicable in the case in hand having regard to the facts and circumstances of the case. Thus, when the claims of the assessee have been duly examined during original assessment proceedings and also the reassessment proceedings under Section 153A of the Act itself, there could have be…

Raghav Bahl, Delhi vs. Deputy Commissioner of Income Tax, Central Circle- 1, Noida

In the result, the captioned appeals filed by the assessees are allowed

ITA 1827/DEL/2024[2019-20]Status: DisposedITAT Delhi20 Jun 2025AY 2019-20

Bench: Ms. Madhumita Roy & Shri Naveen Chandraa.Y. 2013-14 A.Y. 2014-15 A.Y. 2015-16 A.Y. 2016-17 A.Y. 2017-18 A.Y. 2019-20 A.Y. 2018-19

Section 24Section 263Section 263(1)

…n taken by the AO in the assessment order the same cannot be held to be prejudicial to the interests of Revenue. In support of his contention Ld. AR relied upon the decision of the Hon’ble Delhi High Court in the case of CIT v. Sunbeam Auto Pvt. Ltd. [2011] 332 ITR 167 (Del.), which has been duly considered by us and found to be applicable in the case in hand having regard to the facts and circumstances of the case. Thus, when the claims of the assessee have been duly examined during original assessment proceedings and also the reassessment proceedings under Section 153A of the Act itself, there could have be…

Raghav Bahl, Delhi vs. Deputy Commissioner of Income Tax, Central Circle- 1, Noida

In the result, the captioned appeals filed by the assessees are allowed

ITA 1826/DEL/2024[2017-18]Status: DisposedITAT Delhi20 Jun 2025AY 2017-18

Bench: Ms. Madhumita Roy & Shri Naveen Chandraa.Y. 2013-14 A.Y. 2014-15 A.Y. 2015-16 A.Y. 2016-17 A.Y. 2017-18 A.Y. 2019-20 A.Y. 2018-19

Section 24Section 263Section 263(1)

…n taken by the AO in the assessment order the same cannot be held to be prejudicial to the interests of Revenue. In support of his contention Ld. AR relied upon the decision of the Hon’ble Delhi High Court in the case of CIT v. Sunbeam Auto Pvt. Ltd. [2011] 332 ITR 167 (Del.), which has been duly considered by us and found to be applicable in the case in hand having regard to the facts and circumstances of the case. Thus, when the claims of the assessee have been duly examined during original assessment proceedings and also the reassessment proceedings under Section 153A of the Act itself, there could have be…

Raghav Bahl, Delhi vs. Deputy Commissioner of Income Tax, Central Circle- 1, Noida

In the result, the captioned appeals filed by the assessees are allowed

ITA 1825/DEL/2024[2016-17]Status: DisposedITAT Delhi20 Jun 2025AY 2016-17

Bench: Ms. Madhumita Roy & Shri Naveen Chandraa.Y. 2013-14 A.Y. 2014-15 A.Y. 2015-16 A.Y. 2016-17 A.Y. 2017-18 A.Y. 2019-20 A.Y. 2018-19

Section 24Section 263Section 263(1)

…n taken by the AO in the assessment order the same cannot be held to be prejudicial to the interests of Revenue. In support of his contention Ld. AR relied upon the decision of the Hon’ble Delhi High Court in the case of CIT v. Sunbeam Auto Pvt. Ltd. [2011] 332 ITR 167 (Del.), which has been duly considered by us and found to be applicable in the case in hand having regard to the facts and circumstances of the case. Thus, when the claims of the assessee have been duly examined during original assessment proceedings and also the reassessment proceedings under Section 153A of the Act itself, there could have be…

Raghav Bahl, Delhi vs. Deputy Commissioner of Income Tax, Central Circle- 1, Noida

In the result, the captioned appeals filed by the assessees are allowed

ITA 1824/DEL/2024[2015-16]Status: DisposedITAT Delhi20 Jun 2025AY 2015-16

Bench: Ms. Madhumita Roy & Shri Naveen Chandraa.Y. 2013-14 A.Y. 2014-15 A.Y. 2015-16 A.Y. 2016-17 A.Y. 2017-18 A.Y. 2019-20 A.Y. 2018-19

Section 24Section 263Section 263(1)

…n taken by the AO in the assessment order the same cannot be held to be prejudicial to the interests of Revenue. In support of his contention Ld. AR relied upon the decision of the Hon’ble Delhi High Court in the case of CIT v. Sunbeam Auto Pvt. Ltd. [2011] 332 ITR 167 (Del.), which has been duly considered by us and found to be applicable in the case in hand having regard to the facts and circumstances of the case. Thus, when the claims of the assessee have been duly examined during original assessment proceedings and also the reassessment proceedings under Section 153A of the Act itself, there could have be…