PCIT v. V-con Integrated Solutions

476 ITR 526Supreme Court of India2025#7931 most cited

What is PCIT v. V-con Integrated Solutions authority for?

The Assessing Officer's acceptance of the assessee's plea is indicated when they conduct an investigation but make no additions to income, preventing the Commissioner from revising the assessment under section 263 on grounds of lack of enquiry.

14

judgments rely on this decision, according to BharatTax’s citation analysis of 366,314 Indian tax judgments — from 2025 to 2026.

Also referred to as

PCIT v. V-con Integrated Solutions · section 263 · lack of enquiry · assessment order erroneous · prejudicial to the interest of the revenue · Assessing Officer investigation · no addition · Commissioner revision powers

Sections most often in play

Section 143(3)Section 263Section 147Section 148Section 132Section 153ASection 153DSection 80IC

Issues it is cited on

section 153(a)section 80icsection 263(1)section 40a(2)(b)lack of enquiryassessment order erroneoussection 132(1)erroneous and prejudicialsection 254(1)section 80iappeal before cit(a)section 148a(b)

Judgments citing PCIT v. V-con Integrated Solutions

Bscpl Aurang Tollway Limited, Hyderabad vs. DCIT., Circle-1(1), Hyderabad

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

ITA 612/HYD/2024[2018-19]Status: DisposedITAT Hyderabad28 Jan 2026AY 2018-19

Bench: the Tribunal. The assessee has filed an affidavit explaining the reasons for the delay, wherein it was submitted that the appeal for the relevant assessment year was required to be filed within 60 days from the date of receipt of the order passed under Section 263 of the Income-tax Act, 1961. However, the

Section 143(3)Section 263

…to a conclusion that, the A.O. has not examined the issue and has not taken a view. The learned counsel for the assessee, further referring to the decision of the Hon’ble Supreme Court in the case of PCIT Vs. V-Con Integrated Solutions Private Limited (2025) 476 ITR 526 (SC), submitted that, once the A.O. carries out the investigation, but does not make any addition, it can be taken that he accepted the plea of the assessee, and in such case, it would be wrong to say that the Revenue is 18 BSCPL Aurang Tollway Limited remediless. The assessee does not have control over the pen of the A.O. The assessee at best c…

ACIT, CC, Agra vs. Hma Agro Industries Limited, Agra

In the result, ground no.1 raised by the Revenue is accordingly dismissed

ITA 303/AGR/2025[2023-24]Status: DisposedITAT Agra04 Dec 2025AY 2023-24

Bench: Shris.Rifaur Rahman & Shri Sunil Kumar Singhhma Agro Industries Limited, Vs. Dcit, Central Circle, 2/220, 2Nd Floor, Glory Plaza, Agra. Opp. Soor Sadan, M.G. Road, Agra – 282 002. (Pan :Aacch0450J)

For Appellant: Shri Sudhir Sehgal, AdvocateFor Respondent: Shri Arun Kumar Yadav, CIT DR
Section 143(3)Section 147Section 148Section 263Section 40ASection 68

…totally out of context, because in those cases, requisite enquiries had not been made. We are relying upon the judgment of Hon’ble Apex Court in the case of V-Con Integrated Solutions (P.) Ltd. [2025] 173 taxmann.com 774 (SC)/[2025] 304 Taxman 598 (SC)/[2025] 476 ITR 526 (SC)[04-04-2025],where the judgment of Hon’ble Punjab & Haryana High Court cancelling the order of PCIT has been upheld and following finding have been given:- (i) INCOME TAX : SLP dismissed against order of High Court that where Pr. Commissioner invoked revision 10 ITA No.251/Agr/2025 and 4 ors. proceedings on ground that Assessing Officer had…

ACIT, CC, Agra vs. Hma Agro Industries Limited, Agra

ITA 302/AGR/2025[2022-23]Status: DisposedITAT Agra04 Dec 2025AY 2022-23
Section 131Section 143(3)Section 147Section 148Section 263Section 40ASection 68

…totally out of context, because in those cases, requisite enquiries had not been made. We are relying upon the judgment of Hon'ble Apex Court in the case of V-Con Integrated Solutions (P.) Ltd. [2025] 173_taxmann.com 774 (SC)/[2025] 304 Taxman 598 (SC)/[2025] 476 ITR 526 (SC)[04-04-2025],where the judgment of Hon'ble Punjab & Haryana High Court cancelling the order of PCIT has been upheld and following finding have been given:- (i) INCOME TAX : SLP dismissed against order of High Court that where Pr. Commissioner invoked revision proceedings on ground that Assessing Officer had not made sufficient inquiries regar…

ACIT, CC, Agra vs. Hma Agro Industries Limited, Agra

In the result, ground no.1 raised by the Revenue is accordingly dismissed

ITA 301/AGR/2025[2021-22]Status: DisposedITAT Agra04 Dec 2025AY 2021-22

Bench: Shris.Rifaur Rahman & Shri Sunil Kumar Singhhma Agro Industries Limited, Vs. Dcit, Central Circle, 2/220, 2Nd Floor, Glory Plaza, Agra. Opp. Soor Sadan, M.G. Road, Agra – 282 002. (Pan :Aacch0450J)

For Appellant: Shri Sudhir Sehgal, AdvocateFor Respondent: Shri Arun Kumar Yadav, CIT DR
Section 143(3)Section 147Section 148Section 263Section 40ASection 68

…totally out of context, because in those cases, requisite enquiries had not been made. We are relying upon the judgment of Hon’ble Apex Court in the case of V-Con Integrated Solutions (P.) Ltd. [2025] 173 taxmann.com 774 (SC)/[2025] 304 Taxman 598 (SC)/[2025] 476 ITR 526 (SC)[04-04-2025],where the judgment of Hon’ble Punjab & Haryana High Court cancelling the order of PCIT has been upheld and following finding have been given:- (i) INCOME TAX : SLP dismissed against order of High Court that where Pr. Commissioner invoked revision 10 ITA No.251/Agr/2025 and 4 ors. proceedings on ground that Assessing Officer had…

ACIT, CC, Agra vs. Hma Agro Industries Limited, Agra

ITA 300/AGR/2025[2019-20]Status: DisposedITAT Agra04 Dec 2025AY 2019-20

Bench: Shris.Rifaur Rahman & Shri Sunil Kumar Singh

For Appellant: Shri Sudhir Sehgal, AdvocateFor Respondent: Shri Arun Kumar Yadav, CIT DR
Section 143(3)Section 147Section 148Section 263Section 40ASection 68

…totally out of context, because in those cases, requisite enquiries had not been made. We are relying upon the judgment of Hon'ble Apex Court in the case of V-Con Integrated Solutions (P.) Ltd. [2025] 173_taxmann.com 774 (SC)/[2025] 304 Taxman 598 (SC)/[2025] 476 ITR 526 (SC)[04-04-2025],where the judgment of Hon'ble Punjab & Haryana High Court cancelling the order of PCIT has been upheld and following finding have been given:- (i) INCOME TAX : SLP dismissed against order of High Court that where Pr. Commissioner invoked revision proceedings on ground that Assessing Officer had not made sufficient inquiries regar…

Hma Agro Industries Limited, Agra vs. Deputy Commissioner of Income-Tax, Central Circle, Agra

In the result, ground no.1 raised by the Revenue is accordingly dismissed

ITA 251/AGR/2025[2018-2019]Status: DisposedITAT Agra04 Dec 2025AY 2018-2019

Bench: Shris.Rifaur Rahman & Shri Sunil Kumar Singhhma Agro Industries Limited, Vs. Dcit, Central Circle, 2/220, 2Nd Floor, Glory Plaza, Agra. Opp. Soor Sadan, M.G. Road, Agra – 282 002. (Pan :Aacch0450J)

For Appellant: Shri Sudhir Sehgal, AdvocateFor Respondent: Shri Arun Kumar Yadav, CIT DR
Section 143(3)Section 147Section 148Section 263Section 40ASection 68

…totally out of context, because in those cases, requisite enquiries had not been made. We are relying upon the judgment of Hon’ble Apex Court in the case of V-Con Integrated Solutions (P.) Ltd. [2025] 173 taxmann.com 774 (SC)/[2025] 304 Taxman 598 (SC)/[2025] 476 ITR 526 (SC)[04-04-2025],where the judgment of Hon’ble Punjab & Haryana High Court cancelling the order of PCIT has been upheld and following finding have been given:- (i) INCOME TAX : SLP dismissed against order of High Court that where Pr. Commissioner invoked revision 10 ITA No.251/Agr/2025 and 4 ors. proceedings on ground that Assessing Officer had…

Raj Impex, Thane vs. PCIT Central Mumbai 1, Mumbai

Accordingly, are rendered as dismissed

ITA 3719/MUM/2025[2018-19]Status: DisposedITAT Mumbai27 Oct 2025AY 2018-19

Bench: SHRI BEENNA PILLAI (Judicial Member), SHRI ARUN KHODPIA (Accountant Member)

Section 132Section 143(2)Section 143(3)Section 153Section 153ASection 254(1)Section 263Section 80I

…IN THE INCOME TAX APPELLATE TRIBUNAL, ‘D’ BENCH MUMBAI BEFORE: SHRI BEENA PILLAI, JUDICIAL MEMBER & SHRI ARUN KHODPIA, ACCOUNTANT MEMBER & & & & & & Raj Impex Vs. PCIT Central Mumbai 1 101A Devidarshan Complex Room No. 1001, 10th Floor, Tembi Naka Thane West, Pratishtha Bhavan Old CGO Annex Thane-400601. Maharashi Karve Road, PAN: AALFR6800J Mumbai-400020. (Appellant) .. (Respondent) Assessee by Shri. Satish R Mody Revenue by Shri. Umashankar Prasad, CIT. DR Date of Hearing 09/09/2025 Date of Pronouncement 27/10/2025 Order under section 254(1) of Income Tax Act PER BENCH: The captioned appeals are filed by t…

Raj Impex, Thane vs. PCIT Central Mumbai 1, Mumbai

Accordingly, are rendered as dismissed

ITA 3717/MUM/2025[2016-17]Status: DisposedITAT Mumbai27 Oct 2025AY 2016-17

Bench: SHRI BEENA PILLAI (Judicial Member), SHRI ARUN KHODPIA (Accountant Member)

Section 132Section 143(2)Section 143(3)Section 153Section 153ASection 254(1)Section 263Section 80I

…IN THE INCOME TAX APPELLATE TRIBUNAL, ‘D’ BENCH MUMBAI BEFORE: SHRI BEENA PILLAI, JUDICIAL MEMBER & SHRI ARUN KHODPIA, ACCOUNTANT MEMBER & & & & & & Raj Impex Vs. PCIT Central Mumbai 1 101A Devidarshan Complex Room No. 1001, 10th Floor, Tembi Naka Thane West, Pratishtha Bhavan Old CGO Annex Thane-400601. Maharashi Karve Road, PAN: AALFR6800J Mumbai-400020. (Appellant) .. (Respondent) Assessee by Shri. Satish R Mody Revenue by Shri. Umashankar Prasad, CIT. DR Date of Hearing 09/09/2025 Date of Pronouncement 27/10/2025 Order under section 254(1) of Income Tax Act PER BENCH: The captioned appeals are filed by t…

Raj Impex, Thane vs. PCIT Central Mumbai 1, Mumbai

Accordingly, are rendered as dismissed

ITA 3716/MUM/2025[2015-16]Status: DisposedITAT Mumbai27 Oct 2025AY 2015-16

Bench: SHRI BEENAPPILLAI (Judicial Member), SHRI ARUN KHODPIA (Accountant Member)

Section 132Section 143(2)Section 143(3)Section 153Section 153ASection 254(1)Section 263Section 80I

…IN THE INCOME TAX APPELLATE TRIBUNAL, ‘D’ BENCH MUMBAI BEFORE: SHRI BEENA PILLAI, JUDICIAL MEMBER & SHRI ARUN KHODPIA, ACCOUNTANT MEMBER & & & & & & Raj Impex Vs. PCIT Central Mumbai 1 101A Devidarshan Complex Room No. 1001, 10th Floor, Tembi Naka Thane West, Pratishtha Bhavan Old CGO Annex Thane-400601. Maharashi Karve Road, PAN: AALFR6800J Mumbai-400020. (Appellant) .. (Respondent) Assessee by Shri. Satish R Mody Revenue by Shri. Umashankar Prasad, CIT. DR Date of Hearing 09/09/2025 Date of Pronouncement 27/10/2025 Order under section 254(1) of Income Tax Act PER BENCH: The captioned appeals are filed by t…

Raj Impex, Thane vs. PCIT Central Mumbai 1, Mumbai

Accordingly, are rendered as dismissed

ITA 3715/MUM/2025[2013-14]Status: DisposedITAT Mumbai27 Oct 2025AY 2013-14

Bench: SHRI BEENAPPILLAI (Judicial Member), SHRI ARUN KHODPIA (Accountant Member)

Section 132Section 143(2)Section 143(3)Section 153Section 153ASection 254(1)Section 263Section 80I

…IN THE INCOME TAX APPELLATE TRIBUNAL, ‘D’ BENCH MUMBAI BEFORE: SHRI BEENA PILLAI, JUDICIAL MEMBER & SHRI ARUN KHODPIA, ACCOUNTANT MEMBER & & & & & & Raj Impex Vs. PCIT Central Mumbai 1 101A Devidarshan Complex Room No. 1001, 10th Floor, Tembi Naka Thane West, Pratishtha Bhavan Old CGO Annex Thane-400601. Maharashi Karve Road, PAN: AALFR6800J Mumbai-400020. (Appellant) .. (Respondent) Assessee by Shri. Satish R Mody Revenue by Shri. Umashankar Prasad, CIT. DR Date of Hearing 09/09/2025 Date of Pronouncement 27/10/2025 Order under section 254(1) of Income Tax Act PER BENCH: The captioned appeals are filed by t…

Raj Impex, Thane vs. PCIT Central Mumbai 1, Mumbai

Accordingly, are rendered as dismissed

ITA 3714/MUM/2025[2012-13]Status: DisposedITAT Mumbai27 Oct 2025AY 2012-13

Bench: SHRI BEENNA PILLAI (Judicial Member), SHRI ARUN KHODPIA (Accountant Member)

Section 132Section 143(2)Section 143(3)Section 153Section 153ASection 254(1)Section 263Section 80I

…IN THE INCOME TAX APPELLATE TRIBUNAL, ‘D’ BENCH MUMBAI BEFORE: SHRI BEENA PILLAI, JUDICIAL MEMBER & SHRI ARUN KHODPIA, ACCOUNTANT MEMBER & & & & & & Raj Impex Vs. PCIT Central Mumbai 1 101A Devidarshan Complex Room No. 1001, 10th Floor, Tembi Naka Thane West, Pratishtha Bhavan Old CGO Annex Thane-400601. Maharashi Karve Road, PAN: AALFR6800J Mumbai-400020. (Appellant) .. (Respondent) Assessee by Shri. Satish R Mody Revenue by Shri. Umashankar Prasad, CIT. DR Date of Hearing 09/09/2025 Date of Pronouncement 27/10/2025 Order under section 254(1) of Income Tax Act PER BENCH: The captioned appeals are filed by t…

Raj Impex, Thane vs. PCIT Central Mumbai 1, Mumbai

Accordingly, are rendered as dismissed

ITA 3713/MUM/2025[2011-12]Status: DisposedITAT Mumbai27 Oct 2025AY 2011-12

Bench: SHRI BEENNA PILLAI (Judicial Member), SHRI ARUN KHODPIA (Accountant Member)

Section 132Section 143(2)Section 143(3)Section 153Section 153ASection 254(1)Section 263Section 80I

…IN THE INCOME TAX APPELLATE TRIBUNAL, ‘D’ BENCH MUMBAI BEFORE: SHRI BEENA PILLAI, JUDICIAL MEMBER & SHRI ARUN KHODPIA, ACCOUNTANT MEMBER & & & & & & Raj Impex Vs. PCIT Central Mumbai 1 101A Devidarshan Complex Room No. 1001, 10th Floor, Tembi Naka Thane West, Pratishtha Bhavan Old CGO Annex Thane-400601. Maharashi Karve Road, PAN: AALFR6800J Mumbai-400020. (Appellant) .. (Respondent) Assessee by Shri. Satish R Mody Revenue by Shri. Umashankar Prasad, CIT. DR Date of Hearing 09/09/2025 Date of Pronouncement 27/10/2025 Order under section 254(1) of Income Tax Act PER BENCH: The captioned appeals are filed by t…

Ceigall India Limited, Ludhiana vs. Principal Commissioner of Income Tax, Ludhiana

In the result, the appeal of the assessee stands allowed

ITA 540/CHANDI/2025[2020-21]Status: DisposedITAT Chandigarh13 Oct 2025AY 2020-21

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

For Appellant: Shri Sudhir Sehgal, AdvocateFor Respondent: Smt. Tarundeep Kaur, CIT, DR(Virtual)
Section 143(2)Section 143(3)Section 263

…ed his mind and passed a reasoned order. Once due enquiries have been made, the PCIT cannot substitute his judgment. Reliance was placed on Malabar Industrial Co. Ltd. v. CIT (243 ITR 83, SC), Gabriel India Ltd. (203 ITR 108, Bom), V-Con Integrated Solutions (476 ITR 526, SC, 2025) and PCIT v. Aculife Healthcare Pvt. Ltd. (477 ITR 398, SC, 2025). 3.3 The AR submitted that the alleged difference noted by PCIT is misconceived. The assessee paid professional fees of Rs.15.98 crores on which TDS of Rs.1.59 crores was deducted u/s 194J. The balance amount shown under “Legal & Professional Charges”includes items falli…

Vinay Tarachand Chawla, Mumbai vs. Principal Commissioner of Income Tax - 6, Mumbai

In the result, the appeal of the assessee is allowed

ITA 3371/MUM/2025[2020-21]Status: DisposedITAT Mumbai26 Sept 2025AY 2020-21

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal ()

For Appellant: Mr. Ravikant PathakFor Respondent: Mr. Vivek Perampurna, CIT-DR
Section 143(3)Section 2(47)Section 263Section 36(1)(vii)

…as prejudicial to the interest of the Revenue invoking Explanation 2 to Section 263 of the Act. In support thereof the Ld. counsel for the assessee relied on the decision of the Hon'ble Supreme Court in the case of PCIT v. V-Con Integrated Solutions Pvt. Ltd. 476 ITR 526 (SC) wherein the Hon'ble Supreme Court held that the assessee does not control over the pen of the Assessing Officer and once the Assessing Officer carries out the investigation but does not make any addition, it can be taken that he accepts the plea and stand of the assessee. The Hon'ble Supreme Court further held that there may be cases where t…