M. L. Chains v. PCIT

461 ITR 457High Court2024#3925 most cited

What is M. L. Chains v. PCIT authority for?

An assessment cannot be deemed liable for revision under section 263 merely because show-cause notices issued to the taxpayer went un-responded. Such revision directions are not sustainable if the issue has already been decided by case law.

30

judgments rely on this decision, according to BharatTax’s citation analysis of 366,339 Indian tax judgments — from 2025 to 2025.

Also referred to as

M. L. Chains v. PCIT · section 263 · revision directions · show cause notice · un-responded · assessment · unsustainable · PCIT · Principal Commissioner of Income-tax · erroneous and prejudicial

Sections most often in play

Section 263Section 143(3)Section 269-UDSection 133(6)Section 142(1)Section 147Section 1961Section 263 of the Income Tax Act

Issues it is cited on

section 269section 263section 26principal commissioner of income-taxerroneous and prejudicialcompanyinteresttransferindiadocumentsection 143(3)nfac

Judgments citing M. L. Chains v. PCIT

Goyal Brothers, Mainpuri vs. PCIT Agra, Agra

ITA 50/AGR/2022[2017-18]Status: DisposedITAT Agra21 Feb 2025AY 2017-18

Bench: Sh. Satbeer Singh Godara & Sh. Manoj Kumar Aggarwal

For Appellant: Sh. Pankaj Garg, AdvFor Respondent: Sh. Shailenra Srivastava, Sr. DR

…evision authority, an assessment could not be held as liable to be revised merely because of the fact that the corresponding show-cause notice(s) issued to the taxpayer have gone un-responded. We are further informed that case law M. L. Chains Vs. PCIT (2024) 461 ITR 457 (All.) has already decided the very issue involving a similar revision direction, as not sustainable, in para 20 thereof. We thus accept the assessees identical submissions in all these cases to this extent and reverse the learned PCIT's section 263 corresponding identical revision directions. Ordered accordingly. All necessary computation shall…

Girjesh Gupta, Mainpuri vs. PCIT Agra, Agra

ITA 49/AGR/2022[2017-18]Status: DisposedITAT Agra21 Feb 2025AY 2017-18

Bench: Sh. Satbeer Singh Godara & Sh. Manoj Kumar Aggarwal

For Appellant: Sh. Pankaj Garg, AdvFor Respondent: Sh. Shailenra Srivastava, Sr. DR

…ision authority, an assessment could not be held as liable to be revised merely because of the fact that the corresponding show-cause notice(s) issued to the taxpayer have gone un-responded. We are further informed that case law M. L. Chains Vs. PCIT (2024) 461 ITR 457 (All.) has already decided the very issue involving a similar revision direction, as not sustainable, in para 20 thereof. We thus accept the assessees identical submissions in all these cases to this extent and reverse the learned PCIT’s section 263 corresponding identical revision directions. Ordered accordingly. All necessary computation s…

People'S Heritage Hospital Private Limited, Agra vs. Principal Commissioner of Income Tax-1, Agra

ITA 47/AGR/2022[2017-18]Status: DisposedITAT Agra21 Feb 2025AY 2017-18

Bench: Sh. Satbeer Singh Godara & Sh. Manoj Kumar Aggarwal

For Appellant: Sh. Pankaj Garg, AdvFor Respondent: Sh. Shailenra Srivastava, Sr. DR

…ision authority, an assessment could not be held as liable to be revised merely because of the fact that the corresponding show-cause notice(s) issued to the taxpayer have gone un-responded. We are further informed that case law M. L. Chains Vs. PCIT (2024) 461 ITR 457 (All.) has already decided the very issue involving a similar revision direction, as not sustainable, in para 20 thereof. We thus accept the assessees identical submissions in all these cases to this extent and reverse the learned PCIT’s section 263 corresponding identical revision directions. Ordered accordingly. All necessary computation s…

Praveen Kumar Verma, Agra vs. Principal Commissioner of Income Tax, Agra

ITA 40/AGR/2022[2012-13]Status: DisposedITAT Agra21 Feb 2025AY 2012-13

Bench: Sh. Satbeer Singh Godara & Sh. Manoj Kumar Aggarwal

For Appellant: Sh. Pankaj Garg, AdvFor Respondent: Sh. Shailenra Srivastava, Sr. DR

…ision authority, an assessment could not be held as liable to be revised merely because of the fact that the corresponding show-cause notice(s) issued to the taxpayer have gone un-responded. We are further informed that case law M. L. Chains Vs. PCIT (2024) 461 ITR 457 (All.) has already decided the very issue involving a similar revision direction, as not sustainable, in para 20 thereof. We thus accept the assessees identical submissions in all these cases to this extent and reverse the learned PCIT’s section 263 corresponding identical revision directions. Ordered accordingly. All necessary computation s…

Shri Siddhi Vinayak Developers, Agra vs. The Pr CIT -1, Agra

ITA 39/AGR/2022[2016-17]Status: DisposedITAT Agra21 Feb 2025AY 2016-17

Bench: Sh. Satbeer Singh Godara & Sh. Manoj Kumar Aggarwal

For Appellant: Sh. Pankaj Garg, AdvFor Respondent: Sh. Shailenra Srivastava, Sr. DR

…ision authority, an assessment could not be held as liable to be revised merely because of the fact that the corresponding show-cause notice(s) issued to the taxpayer have gone un-responded. We are further informed that case law M. L. Chains Vs. PCIT (2024) 461 ITR 457 (All.) has already decided the very issue involving a similar revision direction, as not sustainable, in para 20 thereof. We thus accept the assessees identical submissions in all these cases to this extent and reverse the learned PCIT’s section 263 corresponding identical revision directions. Ordered accordingly. All necessary computation s…

M/S Tej Shoe Tech, Agra vs. Pr.CIT-1, Agra

ITA 26/AGR/2022[2017-18]Status: DisposedITAT Agra21 Feb 2025AY 2017-18

Bench: Sh. Satbeer Singh Godara & Sh. Manoj Kumar Aggarwal

For Appellant: Sh. Pankaj Garg, AdvFor Respondent: Sh. Shailenra Srivastava, Sr. DR

…ision authority, an assessment could not be held as liable to be revised merely because of the fact that the corresponding show-cause notice(s) issued to the taxpayer have gone un-responded. We are further informed that case law M. L. Chains Vs. PCIT (2024) 461 ITR 457 (All.) has already decided the very issue involving a similar revision direction, as not sustainable, in para 20 thereof. We thus accept the assessees identical submissions in all these cases to this extent and reverse the learned PCIT’s section 263 corresponding identical revision directions. Ordered accordingly. All necessary computation s…

Prashant Kumar Mangal, Agra vs. Principle Commissioner of Income Tax -1., Agra

ITA 107/AGR/2022[2017-18]Status: DisposedITAT Agra21 Feb 2025AY 2017-18

Bench: Sh. Satbeer Singh Godara & Sh. Manoj Kumar Aggarwal

For Appellant: Sh. Pankaj Garg, AdvFor Respondent: Sh. Shailenra Srivastava, Sr. DR

…ision authority, an assessment could not be held as liable to be revised merely because of the fact that the corresponding show-cause notice(s) issued to the taxpayer have gone un-responded. We are further informed that case law M. L. Chains Vs. PCIT (2024) 461 ITR 457 (All.) has already decided the very issue involving a similar revision direction, as not sustainable, in para 20 thereof. We thus accept the assessees identical submissions in all these cases to this extent and reverse the learned PCIT’s section 263 corresponding identical revision directions. Ordered accordingly. All necessary computation s…

M/S Rba Systems (P) Ltd., Agra vs. Pr.CIT., -1, Agra

ITA 46/AGR/2021[2015-16]Status: DisposedITAT Agra21 Feb 2025AY 2015-16

Bench: Sh. Satbeer Singh Godara & Sh. Manoj Kumar Aggarwal

For Appellant: Sh. Pankaj Garg, AdvFor Respondent: Sh. Shailenra Srivastava, Sr. DR

…ision authority, an assessment could not be held as liable to be revised merely because of the fact that the corresponding show-cause notice(s) issued to the taxpayer have gone un-responded. We are further informed that case law M. L. Chains Vs. PCIT (2024) 461 ITR 457 (All.) has already decided the very issue involving a similar revision direction, as not sustainable, in para 20 thereof. We thus accept the assessees identical submissions in all these cases to this extent and reverse the learned PCIT’s section 263 corresponding identical revision directions. Ordered accordingly. All necessary computation s…

Ashok Agarwal, Firozabad vs. Pr.CIT-1, Agra

ITA 39/AGR/2021[2016-17]Status: DisposedITAT Agra21 Feb 2025AY 2016-17

Bench: Sh. Satbeer Singh Godara & Sh. Manoj Kumar Aggarwal

For Appellant: Sh. Pankaj Garg, AdvFor Respondent: Sh. Shailenra Srivastava, Sr. DR

…ision authority, an assessment could not be held as liable to be revised merely because of the fact that the corresponding show-cause notice(s) issued to the taxpayer have gone un-responded. We are further informed that case law M. L. Chains Vs. PCIT (2024) 461 ITR 457 (All.) has already decided the very issue involving a similar revision direction, as not sustainable, in para 20 thereof. We thus accept the assessees identical submissions in all these cases to this extent and reverse the learned PCIT’s section 263 corresponding identical revision directions. Ordered accordingly. All necessary computation s…

Sh. Jagdish Chand, Agra vs. Pr.CIT-1, Agra

Appeal is allowed in above terms

ITA 120/AGR/2022[2017-18]Status: DisposedITAT Agra06 Feb 2025AY 2017-18

Bench: Sh. Satbeer Singh Godara & Sh. M. Balaganesh

For Appellant: NoneFor Respondent: Sh. Sukesh Kumar Jain, CIT-DR
Section 143(3)Section 263

…IN THE INCOME TAX APPELLATE TRIBUNAL AGRA BENCH, AGRA Before Sh. Satbeer Singh Godara, Judicial Member & Sh. M. Balaganesh, Accountant Member ITA No. 120/Agr./2022 : Asstt. Year: 2017-18 Sh. Jagdish Chand, Vs PCIT, Shop No. 8, Raj Shree Talkies, Agra, U.P.-282002 Agra, U.P.-282002 (APPELLANT) (RESPONDENT) PAN No. AINPC1973D Assessee by : None Revenue by : Sh. Sukesh Kumar Jain, CIT-DR Date of Hearing: 06.02.2025 Date of Pronouncement: 06.02.2025 ORDER Per Satbeer Singh Godara, Judicial Member: This assessee’s appeal for Assessment Year 2017-18, arises against the PCIT-1, Agra’s in case No. PCIT- 1/Agra/ITO(OSD)/2…