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“revision u/s 263”

Rectification & RevisionSection 263Section 263521 judgments

The decision most relied on for revision u/s 263 is CIT v. Amitabh Bachchan (384 ITR 200), cited in 264 judgments on BharatTax.

Leading authorities on revision u/s 263

CIT v. Amitabh Bachchan
384 ITR 200 · 2016 · Supreme Court
264
citing judgments

The Commissioner's revisional power under Section 263 of the Income Tax Act is not limited to the points specified in the show-cause notice, nor is the exercise of this power contingent upon issuing a show-cause notice.

Grasim Industries Ltd. v. CIT
321 ITR 92 · 2010 · High Court
194
citing judgments

This case clarifies the scope of the Commissioner's revisional powers under Section 263 of the Income-tax Act, holding that an assessment order can only be revised if it is both erroneous and prejudicial to the interests of the revenue, echoing the principles laid down in Malabar Industrial.

CIT v. Nirma Chemical Works Ltd.
309 ITR 67 · 2009 · High Court
149
citing judgments

An assessment order is not erroneous or prejudicial under Section 263 merely because it is silent on a claim or lacks explicit reasons for its acceptance. Revision under Section 263 is impermissible if the Assessing Officer has taken a plausible view, even if the PCIT holds a different opinion.

Babulal C. Borana v. ITO
282 ITR 251 · 2006 · High Court
138
citing judgments

An assessment order becomes erroneous and prejudicial to the revenue, justifying revision under Section 263, if the Assessing Officer fails to conduct proper inquiries or apply his mind to relevant issues, such as the genuineness of purchases when corresponding sales are accepted, often leading to a remand for fresh adjudication.

CIT v. Jawahar Bhattacharjee
341 ITR 434 · 2012 · High Court
99
citing judgments

An assessment order is erroneous for the purpose of Section 263 if the Assessing Officer fails to apply mind to relevant material, proceeds on an incorrect assumption of facts, or makes an incorrect application of law.

CIT v. Vodafone Essar South Ltd.
212 Taxmann 184 · 2013 · High Court
86
citing judgments

When an Assessing Officer conducts an inquiry and considers the assessee's disclosures, the Commissioner cannot invoke Section 263 to revise the assessment on grounds of inadequate inquiry or a mere difference of opinion. The absence of a detailed discussion on an issue in the assessment order does not automatically mean the Assessing Officer failed to apply his mind.

Principal Commissioner of Income-tax, Surat-2 v. Shreeji Prints (P.) Ltd.
130 Taxmann.com 294 · 2021 · Supreme Court
78
citing judgments

A plausible view taken by the Assessing Officer, after due enquiry and verification, does not render an assessment order erroneous and prejudicial to the interest of revenue for the purpose of revision under Section 263, thereby limiting the scope of revisional powers.

Income-Tax v. Gokuldas Exports
333 ITR 214 · 2011 · High Court
42
citing judgments

An assessment order is not considered erroneous and prejudicial to the interests of the Revenue for invoking Section 263 if the Assessing Officer has adopted one of two possible views, even if the Commissioner of Income-tax disagrees with that view. The phrase 'prejudicial to the interests of the Revenue' must be read in conjunction with the expression 'erroneous'.

Judgments citing revision u/s 263

Directorate of Health Services Employees Co-Operative Society Ltd, Panaji vs. Income Tax Officer, Ward 1(4), Panaji

In the result, appeals of the assessees are allowed

ITA 115/PAN/2022[2017-18]Status: DisposedITAT Panaji21 Aug 2023AY 2017-18

Bench: Shri Partha Sarathi Chaudhury & Shri G.D. Padmahshali(Through Virtual Hearing) Prathamik Krushi Pattin Vs Ito, Ward-1, Sahakari Sangh Niyamit, Nipani Ingali, Tal - Chikodi, Dist. Belgaum, Karnataka. Pan: Aaaap 1335 L Appellant Respondent Directorate Of Health Services Vs Ito, Ward-1(4), Employees Co-Op. Credit Panaji-Goa. Society Ltd., Campal, Panji. Pan: Aaaad 8637 P Appellant Respondent Vyavasaya Seva Sahakari Vs Ito, Ward-2, Sangha Ltd., Kadatoka, Karwar. Honnavar, Karnataka. Pan: Aaaav 0321 N Appellant Respondent

For Appellant: NoneFor Respondent: Shri N. Shrikanth, DR
Section 143(3)Section 263Section 80PSection 80P(2)(a)Section 80P(2)(d)

erroneous and prejudicial to the interests of the revenue. Therefore, he submits that the ld. PCIT was justified in exercising the power of revision u/s 263 of the Act. 10. We heard the rival submissions and perused the material on record. The issue in the present appeal relates

Prathamik Krushi Pattin Sahakari Sangh Nyt, Ingali vs. Income Tax Officer, Ward - 1, Nipani

In the result, appeals of the assessees are allowed

ITA 113/PAN/2022[2012-13]Status: DisposedITAT Panaji21 Aug 2023AY 2012-13

Bench: Shri Partha Sarathi Chaudhury & Shri G.D. Padmahshali(Through Virtual Hearing) Prathamik Krushi Pattin Vs Ito, Ward-1, Sahakari Sangh Niyamit, Nipani Ingali, Tal - Chikodi, Dist. Belgaum, Karnataka. Pan: Aaaap 1335 L Appellant Respondent Directorate Of Health Services Vs Ito, Ward-1(4), Employees Co-Op. Credit Panaji-Goa. Society Ltd., Campal, Panji. Pan: Aaaad 8637 P Appellant Respondent Vyavasaya Seva Sahakari Vs Ito, Ward-2, Sangha Ltd., Kadatoka, Karwar. Honnavar, Karnataka. Pan: Aaaav 0321 N Appellant Respondent

For Appellant: NoneFor Respondent: Shri N. Shrikanth, DR
Section 143(3)Section 263Section 80PSection 80P(2)(a)Section 80P(2)(d)

erroneous and prejudicial to the interests of the revenue. Therefore, he submits that the ld. PCIT was justified in exercising the power of revision u/s 263 of the Act. 10. We heard the rival submissions and perused the material on record. The issue in the present appeal relates

Mumbai Postal Employees Co-Operative Credit Society Ltd, Mumbai vs. Income Tax Officer, Ward 17(2)(1), Mumbai

In the result, both the appeal of the assessee are allowed

ITA 1051/MUM/2023[2016-2017]Status: DisposedITAT Mumbai16 Aug 2023AY 2016-2017

Bench: Shri Amit Shukla & Shri Amarjit Singhita Nos.1050 & 1051/Mum/2023 (A.Ys. 2015-16 & 2016-17) Mumbai Postal Employees Vs. Income Tax Officer, Co-Operative Credit Ward 17(2)(1) Society Limited, Gpo Room No. 115, 1 St Floor, Building, Fort, Kautilya Bhavan, C-41 To Mumbai – 400001 C-43, G Block, Bandra Kurla Complex, Bandra (East), Mumbai – 400051 स्थायी लेखा सं./जीआइआर सं./Pan/Gir No: Aaajm0032G Appellant .. Respondent

For Appellant: Madhur Agarwal &For Respondent: Neena Jeph
Section 143(2)Section 143(3)Section 263Section 80P(2)(a)Section 80P(2)(d)Section 80P(4)

order is erroneous and B the error must be prejudicial to the revenue. Both these conditions need to be simultaneously attracted for revision u/s 263. Refer Malabar Industrial Co Ltd Vs CIT, 243 ITR 83 (SC) and CIT VS. Kwality Steel Suppliers Complex 395 ITR 1 (SC). Annexure ... Addl. CIT 109 ITR 229 (Cal), Annexure 9, which has clarified that where the order is based on ITAT decisions cannot be revised u/s 263 of the Act. vii. Merely because the assessment order does not contain any specific discussions and or reasoning for accepting deduction in full in respect

Mumbai Postal Employees Co-Operative Credit Society Ltd, Mumbai vs. Income Tax Officer, Ward 17(2)(1), Mumbai

In the result, both the appeal of the assessee are allowed

ITA 1050/MUM/2023[2015-16]Status: DisposedITAT Mumbai16 Aug 2023AY 2015-16

Bench: Shri Amit Shukla & Shri Amarjit Singhita Nos.1050 & 1051/Mum/2023 (A.Ys. 2015-16 & 2016-17) Mumbai Postal Employees Vs. Income Tax Officer, Co-Operative Credit Ward 17(2)(1) Society Limited, Gpo Room No. 115, 1 St Floor, Building, Fort, Kautilya Bhavan, C-41 To Mumbai – 400001 C-43, G Block, Bandra Kurla Complex, Bandra (East), Mumbai – 400051 स्थायी लेखा सं./जीआइआर सं./Pan/Gir No: Aaajm0032G Appellant .. Respondent

For Appellant: Madhur Agarwal &For Respondent: Neena Jeph
Section 143(2)Section 143(3)Section 263Section 80P(2)(a)Section 80P(2)(d)Section 80P(4)

order is erroneous and B the error must be prejudicial to the revenue. Both these conditions need to be simultaneously attracted for revision u/s 263. Refer Malabar Industrial Co Ltd Vs CIT, 243 ITR 83 (SC) and CIT VS. Kwality Steel Suppliers Complex 395 ITR 1 (SC). Annexure ... Addl. CIT 109 ITR 229 (Cal), Annexure 9, which has clarified that where the order is based on ITAT decisions cannot be revised u/s 263 of the Act. vii. Merely because the assessment order does not contain any specific discussions and or reasoning for accepting deduction in full in respect

Majestic Properties Pvt. Ltd., New Delhi vs. Pr. CIT, Central- 3, New Delhi

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

ITA 3088/DEL/2018[2013-14]Status: DisposedITAT Delhi10 Aug 2023AY 2013-14

Bench: The Due Date Of Itr Should Have Been Disallowed U/S 43B.”

For Appellant: Dr. Rakesh Gupta, AdvocateFor Respondent: Shri Subhra Jyoti Chakraborty, CIT DR
Section 139(1)Section 143Section 143(3)Section 263Section 271BSection 37Section 43BSection 44A

incorrect allowance of capital expenditure’. Ld. Counsel for the assessee in this regard referred to following case laws for the proposition that revision u/s 263 is not permissible on the basis of the objection of the audit party :- (i) CIT vs. Sohana Woollen Mills

Jagson International Ltd., Delhi vs. DCIT Circle-13(1), Delhi

In the result, the appeal of the assessee is partly allowed for statistical purposes

ITA 902/DEL/2022[2017-18]Status: DisposedITAT Delhi04 Aug 2023AY 2017-18

Bench: Shri Saktijit Dey & Shri M. Balaganeshassessment Year: 2017-18 Jagson International Ltd., Vs Dcit, H-35, 1St Floor, Circle-13(1), Jangpura Extension, Delhi. New Delhi – 110 014. Pan: Aaacj2147A Assessment Year: 2017-18 Dcit, Vs. Jagson International Ltd., H-35, 1St Floor, Circle-13(1), Delhi Jangpura Extension, New Delhi – 110 014. Pan: Aaacj2147A (Appellant) (Respondent) Assessee By : Shri Rajiv Saxena, Ms Sumangla Saxena & Shri Shyam Sunder, Advocates Revenue By : Mohd. Gayasuddin Ansari, Cit, Dr Date Of Hearing : 08.05.2023 Date Of Pronouncement : 04.08.2023

For Appellant: Shri Rajiv SaxenaFor Respondent: Mohd. Gayasuddin Ansari, CIT, DR
Section 115JSection 115VSection 143(3)Section 407

fulfilled by the assessee are essentially question of fact and the AO having allowed the claim for deduction u/s 80-IA, revision u/s 263 was not justified.” 6. This Court has considered the submissions. Section 115VD which defines a ship as "Qualifying Ship" reads as follows : "115VD. For the purposes

JCIT Circle-13(1), New Delhi vs. Jagson International Ltd., New Delhi

In the result, the appeal of the assessee is partly allowed for statistical purposes

ITA 1303/DEL/2022[2017-18]Status: DisposedITAT Delhi04 Aug 2023AY 2017-18

Bench: Shri Saktijit Dey & Shri M. Balaganeshassessment Year: 2017-18 Jagson International Ltd., Vs Dcit, H-35, 1St Floor, Circle-13(1), Jangpura Extension, Delhi. New Delhi – 110 014. Pan: Aaacj2147A Assessment Year: 2017-18 Dcit, Vs. Jagson International Ltd., H-35, 1St Floor, Circle-13(1), Delhi Jangpura Extension, New Delhi – 110 014. Pan: Aaacj2147A (Appellant) (Respondent) Assessee By : Shri Rajiv Saxena, Ms Sumangla Saxena & Shri Shyam Sunder, Advocates Revenue By : Mohd. Gayasuddin Ansari, Cit, Dr Date Of Hearing : 08.05.2023 Date Of Pronouncement : 04.08.2023

For Appellant: Shri Rajiv SaxenaFor Respondent: Mohd. Gayasuddin Ansari, CIT, DR
Section 115JSection 115VSection 143(3)Section 407

fulfilled by the assessee are essentially question of fact and the AO having allowed the claim for deduction u/s 80-IA, revision u/s 263 was not justified.” 6. This Court has considered the submissions. Section 115VD which defines a ship as "Qualifying Ship" reads as follows : "115VD. For the purposes

Au Small Finance Bank Limited, Jaipur vs. Principal Commissioner of Income Tax, Jaipur

In the result, the appeal of the assessee is dismissed

ITA 279/JPR/2023[2018-19]Status: DisposedITAT Jaipur01 Aug 2023AY 2018-19

Bench: SHRI SANDEEP GOSAIN (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Shri Sanjay Jhanwar, Sr. AdvocateFor Respondent: Shri Arvind Kumar, CIT
Section 263Section 36(1)(va)Section 36(1)(viia)Section 36(1)(viii)

erred in directing the Ld. AO for fresh assessment u/s 263 of the Act by alleging that the Assessment Order is liable for revision u/s 263 of the Act to the extent the Ld. AO has allegedly allowed excess deduction of Rs. 16.89 crores with respect to bad debts. written ... order passed u/s 143(3) r.w.s. 143(3A) and 143(3B) of the Act dated 19-03-2021 should not be revised u/s 263 of the Act in a suitable manner. The assessee was given an opportunity to submit its reply. For the sake of convenience, the relevant observation

S.R.Digital and Broadband Pvt.Ltd., Indore vs. PCIT(1), Indore

Appeal is allowed

ITA 38/IND/2022[2016-17]Status: DisposedITAT Indore31 Jul 2023AY 2016-17

Bench: Shri Vijay Pal Rao & Shri B.M. Biyaniassessment Year: 2016-17 S.R. Digital Tv & Pcit, Broadband Private Indore बनाम/ Limited, 335 Orbit Mall, A. B.Road, Vs. Indore. (Assessee / Appellant) (Revenue / Respondent) Pan: Aavcs1165L Assessee By Shri S.S.Solanki, C.A. Revenue By Shri P.K.Mishra, Cit Dr Date Of Hearing 02.05.2023 Date Of Pronouncement 31.07.2023

Section 139(1)Section 143(2)Section 143(3)Section 263Section 80

Indore Bench of ITAT in numerous orders that any issue which is not a part of limited scrutiny cannot form part of revision u/s 263. Therefore, the revision qua this issue is not valid. Ld. DR could not rebut the submission of Ld. AR. He only submitted that

M/S Dbl Jaora Saiana Tollwaya Ltd, Bhopal vs. Pr CIT-1, Bhopal

ITA 147/IND/2020[2015-16]Status: DisposedITAT Indore31 Jul 2023AY 2015-16

Bench: Shri Vijay Pal Rao & Shri B.M. Biyani

For Respondent: Shri P.K. Mishra, CIT DR
Section 143(3)Section 263

through the relevant material on record. It can be seen from para 4 of the ld. CIT‟s order that: “A proposal for revision u/s 263 of the IT Act, 1961 was received from DCIT(IT)-1, Pune through the Jt.CIT(IT), Pune vide letter No. Pn/Jt.CIT(IT)/263/2016-17/61 dated ... Bhopal ITA Nos. 144 to 147/Ind/2020 Assessment year 2015-16 considers erroneous and prejudicial to the interests of revenue. The process of revision u/s 263 of the Act initiates only when the CIT calls for and examines the record of any proceeding under this Act and considers that any order

M/S Dbl Ashoknagar Vidisha Tollways Ltd, Bhopal vs. Pr CIT-1, Bhopal

ITA 146/IND/2020[2015-16]Status: DisposedITAT Indore31 Jul 2023AY 2015-16

Bench: Shri Vijay Pal Rao & Shri B.M. Biyani

For Respondent: Shri P.K. Mishra, CIT DR
Section 143(3)Section 263

through the relevant material on record. It can be seen from para 4 of the ld. CIT‟s order that: “A proposal for revision u/s 263 of the IT Act, 1961 was received from DCIT(IT)-1, Pune through the Jt.CIT(IT), Pune vide letter No. Pn/Jt.CIT(IT)/263/2016-17/61 dated ... Bhopal ITA Nos. 144 to 147/Ind/2020 Assessment year 2015-16 considers erroneous and prejudicial to the interests of revenue. The process of revision u/s 263 of the Act initiates only when the CIT calls for and examines the record of any proceeding under this Act and considers that any order

M/S Dbl Tikaamgarh Nowgon, Bhopal vs. Pr CIT -1, Bhopal

ITA 145/IND/2020[2015-16]Status: DisposedITAT Indore31 Jul 2023AY 2015-16

Bench: Shri Vijay Pal Rao & Shri B.M. Biyani

For Respondent: Shri P.K. Mishra, CIT DR
Section 143(3)Section 263

through the relevant material on record. It can be seen from para 4 of the ld. CIT‟s order that: “A proposal for revision u/s 263 of the IT Act, 1961 was received from DCIT(IT)-1, Pune through the Jt.CIT(IT), Pune vide letter No. Pn/Jt.CIT(IT)/263/2016-17/61 dated ... Bhopal ITA Nos. 144 to 147/Ind/2020 Assessment year 2015-16 considers erroneous and prejudicial to the interests of revenue. The process of revision u/s 263 of the Act initiates only when the CIT calls for and examines the record of any proceeding under this Act and considers that any order

M/S Dbl Betul Sarmi Tollwayas, Bhopal vs. Pr CIT-1, Indore

ITA 144/IND/2020[201516]Status: DisposedITAT Indore31 Jul 2023

Bench: Shri Vijay Pal Rao & Shri B.M. Biyani

For Respondent: Shri P.K. Mishra, CIT DR
Section 143(3)Section 263

through the relevant material on record. It can be seen from para 4 of the ld. CIT‟s order that: “A proposal for revision u/s 263 of the IT Act, 1961 was received from DCIT(IT)-1, Pune through the Jt.CIT(IT), Pune vide letter No. Pn/Jt.CIT(IT)/263/2016-17/61 dated ... Bhopal ITA Nos. 144 to 147/Ind/2020 Assessment year 2015-16 considers erroneous and prejudicial to the interests of revenue. The process of revision u/s 263 of the Act initiates only when the CIT calls for and examines the record of any proceeding under this Act and considers that any order

Swastik Corporation, Vapi vs. Pr. CIT 3, Valsad

In the result, appeal of the assessee is allowed

ITA 21/SRT/2021[2012-13]Status: DisposedITAT Surat31 Jul 2023AY 2012-13

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकरअपीलसं./Ita No.21/Srt/2021 ("नधा"रणवष" / Assessment Year: (2012-13) (Virtual Court Hearing) M/S Swastik Corporation The Principal Commissioner Of Income Tax-3, Room No.301, 3Rd Floor, Palak A-305, Surya Co-Operative Vs. Housing Society Ltd., Plot Arcade, Pali Hill Shanti Nagar, Tithal No.61, Vapi-396195 Road,Valsad-396001 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Abtfs 1028 G अपीलाथ"/ Appellant ""थ" / Respondent

Section 143(3)Section 144Section 147Section 148Section 184(5)Section 234A(1)Section 263Section 40

erroneous order which goes against the interest of Revenue collection. We note that order which has merged with appellate order cannot be revised u/s 263 of the Act. The ld PCIT has powers to revise only orders of the Assessing Authorities which ware erroneous and prejudicial to the interest ... r.w.s.147 of the Act dated 30.08.2017, was passed by Assessing Officer, by making part addition on the issue which was subject matter of revision u/s 263 by ld PCIT. The Assessing Officer has passed the assessment order after 21/SRT/2021 AY.12-13 M/s Swastik Corporation examination of debited amount of Rs.10

Au Small Finance Bank Limited, Jaipur vs. Principal Commissioner of Income Tax, Jaipur-1

In the result both the appeals filed by the assessee in ITA

ITA 203/JPR/2022[2017-18]Status: DisposedITAT Jaipur28 Jul 2023AY 2017-18

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Shri Sanjay Jhanwar, Sr. AdvocateFor Respondent: Shri James Kurian, CIT
Section 115JSection 263Section 35ASection 36(1)(viia)

grossly erred in directing the AO for fresh assessment u/s 263 of the Act by holding that the assessment order is liable for revision u/s 263 of the Act to the extent the AO has allegedly allowed excess deduction of Rs.22.69 crores u/s 36(1)(viia ... erred in directing the Ld. AO for fresh assessment u/s 263 of the Act by holding that the Assessment Order is liable for revision u/s 263 of the Act to the extent the Ld. AO has allegedly allowed excess deduction of Rs. 22.69 crores u/s 36 (1)(viia

Nitin Gupta, Bhopal vs. Pr. Commissioner of Income Tax-2, Bhopal

In the result, appeal of assessee is allowed for statistical purposes

ITA 221/IND/2018[2010-11]Status: DisposedITAT Indore27 Jul 2023AY 2010-11

Bench: Shri Vijay Pal Rao & Shri B.M. Biyaninitin Gupta Pr. Cit-2 H.No.36 Kainchi Chhola Bhopal Vs. Road, Chhola Bhopal (Appellant / Assessee) (Respondent/ Revenue) Pan: Ajupg 6497Q Assessee By Shri Gagan Tiwari, Ar Revenue By Shri P.K. Mishra, Cit- Dr Date Of Hearing 26.07.2023 Date Of Pronouncement 27 .07.2023

Section 143(1)Section 147Section 148Section 263

case, the Ld. CIT has grievously erred in not allowing proper, reasonable and meaningful opportunity before taking the assessment Order in Suo Moto revision u/s 263. 2. That on facts and in the circumstances of the case, the launching of proceedings u/s 263 of Income

Suman Kumar Anand, Bhopal vs. The PCIT-1, Bhopal

Appeal is dismissed

ITA 416/IND/2022[017-18]Status: DisposedITAT Indore20 Jul 2023

Bench: Shri Vijay Pal Rao & Shri B.M. Biyaniassessment Year: 2017-18 Shri Suman Kumar Principal Cit-1, Anand, Bhopal बनाम/ 22,Lala Lajpat Rai Colony, Raisen Road, Vs. Bhopal (Assessee / Appellant) (Revenue / Respondent) Pan: Aebpa7192N Assessee By Ms. Nisha Lahoti & Shri Vijay Bansal, Ars Revenue By Shri P.K.Mishra, Cit Dr Date Of Hearing 20.07.2023 Date Of Pronouncement 21.07.2023

Section 143(3)Section 263Section 54F

exemption u/s 54F. Accordingly, the PCIT termed the assessment-order as erroneous-cum-prejudicial to the interest of revenue and initiated action of revision u/s 263. Finally, Ld. PCIT passed the impugned revision-order thereby he set aside the assessment- order with a direction to AO to make de novo

M/S Vikram Developers Private Limited, Mumbai vs. Principle Commissioner of Income Tax-8, Mumbai

Appeal is allowed

ITA 1357/MUM/2023[2018-2019]Status: DisposedITAT Mumbai19 Jul 2023AY 2018-2019
For Appellant: Shri Navin B GandhiFor Respondent: Shri Ankush Kapoor
Section 142(1)Section 143(1)(a)Section 143(2)Section 143(3)Section 263Section 43C

incorrect application of law and is made after taking all the relevant documents, justification, inquiries/verification into consideration and does not warrant any revision u/s 263. Relief Claimed The revision order dated 30-03-2023 passed u/s 263 setting aside the assessment order dated 27-03-2021 is not warranted

Dinesh Kumar Chaurasia, Tonk vs. PCIT Central, Jaipur

In the result, appeal of the assessee is dismissed

ITA 102/JPR/2023[2018-19]Status: DisposedITAT Jaipur17 Jul 2023AY 2018-19

Bench: SHRI SANDEEP GOSAIN (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Sh. Mahendra Gargieya (Adv.)For Respondent: Sh. Ajey Malik (CIT)
Section 143(3)Section 263Section 5

following words: “6. The reply of the taxpayer has been studied. The crux of assessee’s counter is on procedural aspects largely towards revision u/s 263 of the Income-tax Act, 1961, rather than on merits of the matter. Even on procedural aspects, the assessee’s counter is weak

Spectrum Infonet Pvt. Ltd., Raigarh vs. Pr. Commissioner of Income Tax (Central), Bhopal

In the result, appeal filed by the assessee in ITA No

ITA 34/RPR/2022[2011-12]Status: DisposedITAT Raipur14 Jul 2023AY 2011-12

Bench: Shri Ravish Sood & Shri Arun Khodpiaआयकर अपील सं. / Ita Nos. 33 & 34/Rpr/2022 "नधा"रण वष" / Assessment Years : 2010-11 & 2011-12 Spectrum Infonet Private Limited 601, South Gajanandpuram Colony, Kotra Road, Raigarh (C.G.)-496001 Pan : Aalcs5656E .......अपीलाथ" / Appellant बनाम / V/S. The Pr. Commissioner Of Income Tax (Central), Bhopal ……""यथ" / Respondent

For Appellant: Shri R.B Doshi, CAFor Respondent: Shri V.K Singh, CIT-DR
Section 147Section 263

necessary verification while framing assessment and summarily accepting the explanation of the assessee would render the order passed by him amenable for revision u/s 263 of the Act is supported by the judgment of the Hon’ble Supreme Court in the case of Deniel Merchants