“revision u/s 263”

DCIT-4(1), INDORE, INDORE vs. ODDIVILLE FOODS AND FROZEN, INDORE

Accordingly, the grounds raised by the Revenue are dismissed\nand the order of the Ld

situation involved in present\ncase of assessee. Therefore, those decisions cannot help assessee. He also\nsubmitted that had there been no action of revision u/s 263 by Ld. PCIT,\nthe assessee would have not filed Form No. 10CCB. He submitted that filing\nof Form No. 10CCB is mandatory for claiming

CLAYMINE MICRONS LLP,WANKANER vs. PRINCIPAL CIT 1, RAJKOT

In the result, the appeal of the assessee in ITA No

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinhaआयकर अपील सं. / Ita No. 216/Rjt/2024 Assessment Year: (2018-19) (Physical Hearing) Claymine Microns Llp Vs. Pcit Survey No. 59 At Ratavirda, Nr. Capron Aayakar Bhawan, Race Course Ceramic Sartanpar Road, Wankaner, Ring Road, Rajkot, Gujarat - Gujarat - 363641 360001 Pan/Gir No.: Aamfc4286C (Assessee) (Respondent) िनधा"रती की ओर से/Assessee By : Shri Hardik Vora, Ar राज" की ओर से/Respondent By : Shri Sanjay Punglia, Cit. Dr सुनवाई की तारीख/Date Of Hearing : 16/02/2026 घोषणा की तारीख/Date Of Pronouncement : 11/03/2026

found to be acceptable or satisfactory, the partners’ capital contribution cannot be taxed in the hands of the assessee- firm. Therefore, the proposed revision u/s 263 of the Act in the hands of assessee- firm is completely unjustified and in direct contradiction to the legal position settled

M/S. THDC INDIA LIMITED,RISHIKESH vs. THE PRINCIPAL COMMISSIONER OF INCOME TAX, DEHRADUN

In the result, appeal of the assessee is allowed

Bench: Shri Yogesh Kumar U.S & Shri Manish Agarwal[Through Virtual Mode] [Assessment Year : 2017-18] M/S. Thdc India Ltd. Vs Pcit Ganga Bhawan, Aaykar Bhawan, Pragatipuram, Bye Pass 13 A, Subhash Road, Road, Rishikesh, Uttarakhand Uttarakhand-249201 Pan-Aaact7905Q Appellant Respondent Assessee By Shri Jeetan Nagpal, Ca Shri Sanjay Arora, Ca & Ms. Pallavi, Ca Revenue By Ms. Poonam Sharma, Cit Dr Date Of Hearing 08.12.2025 Date Of Pronouncement 18.02.2026 Order Per Manish Agarwal, Am : The Present Appeal Is Filed By The Assessee Against The Order Dated 27.03.2022 By Ld. Pr. Commissioner Of Income Tax, Dehradun [“Ld. Pcit”] Passed U/S 263 Of The Income Tax Act, 1961 [“The Act”] Arising From The Assessment Order Dated 30.12.2019 Passed U/S 143(3) Of The Act Pertaining To Assessment Year 2017-18. 2. Brief Facts Of The Case Are That The Assessee Is A Joint Venture Company Of Government Of India & Government Of Uttar Pradesh & Engaged In The Business Of Generation & Supply Of Hydro- Electric As Well As Wind Power & Also Engaged In Construction Of Hydro Power Plants. The Return Of Income Was Filed On 30.10.2017, Declaring Total Income Of Inr 6,84,04,420/- After Claiming Deduction U/S 80-Ia Of The Act Of Inr 948,40,76,282/-. The Book Profits Was Shown At Inr 7,84,96,09,382/- & Mat Of Inr 1,67,52,32,236/- Was Paid. The Case Of The Assessee Was Selected For Scrutiny & After Considering The Submissions Made, Total Income Was Assessed At Inr 4,63,78,80,698/- By Making Disallowance Out Of Deduction Claimed U/S 80-Ia Of The Act To The Extent Of Inr 211,15,54,378/- & Further Making Addition Of Inr 245,79,21,900/- On Account Of Late Payment Surcharge On Outstanding Debtors For The Period Of 10 Months Holding The Same As Taxable On Accrual Basis & No Deduction U/S 80Ia Was Allowed On Such Addition.

appeal was filed before the ld. CIT(A) which is pending as on date, thus this issue cannot be made subject matter of revision u/s 263 of the Act. 9. Ld. AR further submits that when the AO has made enquiries which is evident from the fact that the addition ... state that adequate enquiries with regard to claim of deduction u/s 80IA of the Act were not made by the ld AO warranting revision u/s 263 of the Act. 9. With regard to specific allegation leveled by the ld PCIT in the aspect of capacity charges not having first degree

SUNIL KUMAR BAHETI,SURAT vs. PCIT (CENTRAL), SURAT

In the result, the appeal of the assessee is allowed

Bench: Dr. B.R.R. Kumar, Vice-Ms. Suchitra Kamble

accepting the returned income. Subsequently, the Ld. PCIT examined the assessment records and issued show-cause notices dated 07.03.2025 and 28.03.2025 proposing revision u/s 263 of the Act on two issues: (i) Alleged unexplained cash investment of Rs.27,87,450/- for purchase of shop No. 547 based on seized documents ... assessment. The Ld. AR, therefore, contended that the issue was subject to due enquiry and application of mind by the Assessing Officer, and revision u/s 263 amounts to mere change of opinion. As regards house property income, the Ld. AR submitted that the properties were either used for business Sunil

SHRI SUCHHA SINGH THROUGH L/R RANJIT SINGH,KAPUTHALLA vs. PRINCIPAL COMMISSIONER OF INCOME TAX -1, JALANDHAR

Bench: Hon’Ble Shri Manoj Kumar Aggarwal, Am & Shri Udayan Dasgupta, Jm

assessee. After due consideration, Ld. AO accepted the returned income vide assessment order dated 25-12-2018. This order was subjected to revision u/s 263 wherein it was alleged that no plausible explanation was furnished by the assessee on the investment so made in the immovable property. The assessment ... make belief of escapement of income. The reassessment was initiated on mere borrowed satisfaction and therefore, the order could not be subjected to revision u/s 263. The assessee denied having undertaken any such transaction. This being so, the revisional jurisdiction u/s 263 could not have been invoked