“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

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

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

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

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

Ashok Kumar Jain, Meerut vs. PCIT, Ghaziabad

In the result, both the appeals filed by appellant/assessee are allowed

ITA 2627/DEL/2024[2013-14]Status: DisposedITAT Delhi06 Jun 2025AY 2013-14

Bench: Shri Vimal Kumar & Shri Brajesh Kumar Singhita No. 2627/Del/2024 Assessment Year: 2013-14 Ita No.2628/Del/2024 Assessment Year: 2014-15 Ashok Kumar Jain, Vs. Principal Cit, Prop. Mange Lal Prakash Ghaziabad Chand, 45-B Gupta Colony, (Uttar Pradesh) T.P. Nagar, Meerut Pin: 250002 Pan: Aeipj3089E (Appellant) (Respondent) Assessee By: Shri Piyush Agarwal, Ca Department By: Mr. Javed Akhtar, Cit (Dr) Date Of Hearing: 20.03.2025 Date Of Pronouncement: 06.06.2025 O R D E R Per Vimal Kumar: The Appeals Filed By The Appellant/Assessee Are Against Separate Orders Dated 27.03.2024 Of Learned Principal Commissioner Of Income-Tax(Appeals), Ghaziabad (Hereinafter Referred As ‘Ld. Pcit’ ) Under Section 263 Of The Income-Tax Act, 1961 (Hereinafter Referred As “The Act”) Arising Out Of Separate Assessment Orders, Both Dated 29.03.2022 Of National Faceless Appeal Centre(Nfac), Delhi (Hereinafter Referred As “Ld. Ao”) Under Section 147 R.W.S. 144B Of The Act For Assessment Years 2013-14 & 2014-15 Respectively.

For Appellant: Shri Piyush Agarwal, CAFor Respondent: Mr. Javed Akhtar, CIT (DR)

Section 142(1)Section 143(2)Section 143(3)Section 147Section 148Section 151Section 263Section 40Section 40A(3)

dated 09.03.2022 also AO has not disposed all the objections raised by the appellant, so the reassessment order is void ab initio and revision u/s 263 of a void assessment order cannot be sustained 4. Ld. AO passed reassessment order on 29.03.2022 within 4 weeks of disposing of objections ... violation oflaw as per the decision of various higher courts, so as per law the reassessment order is void ab initio and revision u/s 263 of a void assessment order cannot be sustained. 5. The appellant craves leave to add, alter, amend, delete or withdraw one or more grounds

N R Corporation, Surat vs. PCIT-1, Surat

In the result, the appeal of the assessee is allowed

ITA 526/SRT/2024[2018-19]Status: DisposedITAT Surat28 May 2025AY 2018-19

Bench: Shri Pawan Singh & Shri Bijayananda Prusethआयकर अपील सं./Ita No.526/Srt/2024 Assessment Year: 2018-19 (Physical Hearing) N. R. Corporation, Vs. The Pcit - 1, B-202, Capital Status, Opp – Hariom Surat Nagar, Near Atman Park, L. P. Savani Road, Adajan, Surat - 395009 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aamfn9368A (Appellant) (Respondent) Appellant By Shri Suresh K. Kabra, Ca Respondent By Shri Ritesh Mishra, Cit-Dr Date Of Hearing 13/03/2025 Date Of Pronouncement 28/05/2025

Section 143Section 143(2)Section 143(3)Section 194CSection 263Section 40

erroneous insofar as prejudicial to the interests of justice u/s 263 of the Act. Hence, ld. PCIT issued show cause notice proposing revision u/s 263 of the Act. In reply, the assessee submitted that TDS was deducted and paid in due course on all amount of expenditure (Annexure – A1). Copy

Neha Goel, Faridabad vs. PCIT, Faridabad

In the result, appeal of the assesse is allowed

ITA 2624/DEL/2024[2014-15]Status: DisposedITAT Delhi28 May 2025AY 2014-15

Bench: Sh. Shamim Yahya & Sh. Sudhir Kumarassessment Year: 2014-15 Neha Goel, Vs. Pcit, H. No. 585 Sector 15 Faridabad. Faridabad 121007. Pan No.Ahcpg6493Q (Appellant) (Respondent)

Section 10(38)Section 144BSection 147Section 148Section 148(2)Section 151Section 263

applicable binding CBDT instructions/guidelines 2. That impugned revision order passed u/s 263 of the Act is invalid as no revision u/s 263 can take place qua assessment order passed in faceless mode u/s 144B of the Act as per very scheme of the 1961 Act.” 3. The brief facts

M/S. Simero Vitrified P. Ltd., Morbi vs. The Pr. CIT-3, Rajkot

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

ITA 276/RJT/2019[2016-17]Status: DisposedITAT Rajkot22 May 2025AY 2016-17

Bench: Us Is A Private Limited Company & Engaged In The Business Of Manufacturing Of Vitrified Tiles. The Return Of Income Has Been E-Filed By The Assessee, On 10/09/2016 For Assessment Year (A.Y.) 2016-17, Reporting Loss Of Rs. 5,68,00,829/-, Which Was Later Revised On 09/03/2018, Declaring Total Loss Of Rs. 13,97,40,413/-, Claiming Investment Allowance U/S 32Ac Of The Income Tax Act. The Case Has Been Selected For Complete Scrutiny (Cass) Specifically To Examine The Followings: 1) Whether Outward Foreign Remittance Is From Disclosed Sources & Appropriate Withholding & Reporting Obligation Have Been Complied With; 2) Whether Investment & Income Relating To Properties Are Duly Disclosed; 3) Whether Receipt Of Foreign Remittance Has Been Correctly Offered For Tax And, 4) Whether Sundry Creditors Are Genuine. 4. The Assessment Order U/S 143(3) For The Assessment Year (A.Y.) 2016-17 Was Passed By Dcit, Morbi Circle, Morbi, Being The Assessing Officer (Ao), On 21/12/2018, Allowing The Loss Claimed Of Rs. 13,97,40,413/- To Be Carry Forward To Subsequent Years. 2

Section 143(3)Section 263Section 32ASection 68

Thereafter, Pr. Commissioner of Income Tax-3, Rajkot found some discrepancies in passed assessment and on the basis of their judgement, order for revision u/s 263 was passed on 13.09.2016 and AO was directed to re-assess the income of the assessee depicting the following issues: (a) Share Capital introduced

Nature Commercial Pvt Ltd, Delhi vs. ITO, Ward-2(1), Kolkata

In the result, appeal of the assessee stands allowed

ITA 853/KOL/2024[2008-09]Status: DisposedITAT Kolkata22 May 2025AY 2008-09

Bench: Shri Rajesh Kumar, Am& Shri Pradip Kumar Choubey, Jm]

Section 131Section 133(6)Section 142(1)Section 143(3)Section 147Section 148Section 250Section 263Section 68

amended by invoking powers conferred u/s 263 of the Act and when re-assessment order itself is bad in law, same cannot" be revised u/s 263, since, only valid re-assessment order can be revised u/s 263. It may be noted that the appellant cannot challenge the validity ... assessment order passed by the Assessing Officer is erroneous and prejudicial to the interest of revenue Therefore, your case is being considered for revision u/s 263 of the Income Tax Act, 1961. However, before making any such order of revision, you are allowed an opportunity to appear before the undersigned

Wind Financial Services LLP, Daman & Diu vs. PCIT, Valsad

In the result, the appeal of the assessee is allowed

ITA 502/SRT/2024[2015-16]Status: DisposedITAT Surat21 May 2025AY 2015-16

Bench: Shri Pawan Singh & Shri Bijayananda Prusethआयकर अपील सं./Ita Nos.501 & 502/Srt/2024 (Ays: 2014-15 & 2015-16) (Hybrid Hearing) Wind Financial Services Llp, Vs. The Pcit, [Formerly Known Wind Financial Valsad Services Pvt. Ltd.] Shop No.102/A, 436 Sq Feet Built Up, Dabhel, Daman & Diu, Valsad – 396215 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aadfw6369H (Appellant) (Respondent) Appellant By Shri S. N. Divetia, Ar Respondent By Shri Ritesh Mishra, Cit-Dr Date Of Hearing 12/03/2025 Date Of Pronouncement 21/05/2025 आदेश / O R D E R Per Bijayananda Pruseth, Am: These Appeals By The Assessee Emanate From The Orders Passed Under Section 263 Of The Income-Tax Act, 1961 (In Short, ‘The Act’) By The Learned Principal Commissioner Of Income Tax, Valsad [In Short, ‘Ld. Pcit’], Dated 16.03.2024 For Assessment Years (Ays) 2014-15 & 2015-16. Since Facts Of The Cases & The Grounds Taken Up In The Appeals Are Similar Except Variation In The Amount, These Appeals Were Heard Together & A Common Order Is Passed For The Sake Of Convenience & Brevity. Ita No. 501/Srt/2024 Is Taken As The ‘Lead Case’.

Section 142(1)Section 143(3)Section 147Section 148Section 263

facts in not considering fully and properly the submissions made and evidence produced by the appellant with regard to the impugned exercise of revision u/s 263. 2.1 The Ld. Pr. CIT has grievously erred in law and on facts in holding that the assessment order passed u/s 147 r.w.s. 144B ... erroneous and prejudicial to the interest of Revenue so that action of revision u/s 263 was justified. 2.2 The Id. Pr. CIT has erred in law and or on facts in invoking the powers of revision u/s 263 of the Act, since the condition precedent were not satisfied. 2.3 That

Wind Financial Services LLP, Daman & Diu vs. PCIT, Valsad

In the result, the appeal of the assessee is allowed

ITA 501/SRT/2024[2014-15]Status: DisposedITAT Surat21 May 2025AY 2014-15

Section 142(1)Section 143(3)Section 147Section 148Section 263

International Switchgears Private Ltd., Chandigarh vs. Pr. CIT-1, Chandigarh

The appeal stands dismissed

ITA 395/CHANDI/2022[2017-18]Status: DisposedITAT Chandigarh14 May 2025AY 2017-18

Bench: Hon’Ble Shri Rajpal Yadav & Hon’Ble Shri Manoj Kumar Aggarwal, Am आयकरअपीलसं./ Ita No.395/Chandi/2022 (िनधा"रणवष" / Assessment Year: 2017-18) M/S International Switchgears Pvt. Ltd. Pcit Plot No. 925-A, Industrialareaphase-Ii Chandigarh बनाम/ Vs. Chandigarh-160017 "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aaaci-6305-F (अपीलाथ"/Appellant) (""थ" / Respondent) : अपीलाथ"कीओरसे/ Appellant By : Shri Aditya Jain (Ca) - Ld. Ar ""थ"कीओरसे/Respondent By : Shri Rohit Sharma (Cit) – Ld. Dr सुनवाईकीतारीख/Date Of Hearing : 04-03-2025 घोषणाकीतारीख /Date Of Pronouncement : 14-05-2025 आदेश / O R D E R Manoj Kumar Aggarwal () 1. By Way Of This Appeal, The Assessee Assails Invocation Of Revisionary Jurisdiction U/S 263 By Ld. Pr. Commissioner Of Income Tax, Chandigarh-1 (Pr.Cit) For Assessment Year (Ay) 2017-18 Vide Impugned Order Dated 30-03-2022 In The Matter Of An Assessment Framed By Ld. Ao U/S.143(3) Of The Act On 17-12-2019. Having Heard Rival Submissions & Upon Perusal Of Case Records, The Appeal Is Disposed-Off As Under. The Assessee Being Resident Corporate

For Appellant: Shri Aditya Jain (CA) - Ld. ARFor Respondent: Shri Rohit Sharma (CIT) – Ld. DR

Section 143(3)Section 263Section 80Section 80I

issues were not enquired / verified by Ld. AO. On these facts, in our considered opinion, the assessment order has rightly been subjected to revision u/s 263. Accordingly, we see no reason to interfere in the same. However, our aforesaid adjudication would not be construed to have any expression on merits

Shri Balbir Singh Verma, Shimla vs. Pr.CIT, Shimla

In the result, appeal of the Assessee is allowed

ITA 314/CHANDI/2020[2015-16]Status: DisposedITAT Chandigarh14 May 2025AY 2015-16

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

For Appellant: Shri Parikshit Aggarwal, C.AFor Respondent: Shri Rohit Sharma, CIT DR (Virtual)

Section 133ASection 142(1)Section 143(2)Section 143(3)Section 24Section 263Section 271(1)(c)Section 36(1)(iii)

expenditure of an item in a subsequent year can not make the assessment order for an earlier year to be subject to revision u/s 263. Thirdly, the Pr. CIT’s concern about future deduction is speculative and outside the scope of Section 263, which applies only when the order

M/S. Sarju Vitrified Pvt. Ltd., Morbi-363641 vs. The Pr. CIT-1, Rajkot

ITA 83/RJT/2023[2018-19]Status: DisposedITAT Rajkot24 Apr 2025AY 2018-19

Section 142(1)Section 143(3)Section 263Section 68Section 68o

nature and source of credit with sufficient documentary evidences and when such evidences are not disproved or found to be false, no revision u/s 263 can be proposed. C. OBSERVATION: Some of the bank accounts of the investors contain cash deposits, which are immediately invested in your company. REPLY: This

Mmtc Ltd vs. DCIT Circle 5(1)

In the result the appeal of the assessee is allowed

ITA 2732/DEL/2006[2004-2005]Status: DisposedITAT Delhi23 Apr 2025AY 2004-2005

Bench: Shri M. Balaganesh & Shri Yogesh Kumar U.S.Clix Capital Services Pvt. Ltd, Vs. Pcit, Plot No. 23, 5Th Floor, Aggarwal Delhi-1, Delhi Corporate Tower Govind Lal Sikka Marg, Rajendra Place, West Delhi, New Delhi, Delhi, India, 110008 (Appellant) (Respondent) Pan: Aaacc0642F

For Appellant: Shri Ajay Vohra, Sr. AdvFor Respondent: Shri Sanjay Kumar Bharati, CIT DR

Section 139(1)Section 143(3)Section 144BSection 263Section 37

provision for expenses. Hence, we hold that there is no error in the order of the ld AO in this regard warranting revision u/s 263 of the Act. 12. Cost Allocation charges amounting to Rs. 12.07 crores. The ld AR drew our attention to para 24.1 of notes of account ... view of the fact that if the proposition of the ld DR is accepted, then all the assessments would be eligible for revision u/s 263 of the Act irrespective of the fact whether adequate enquiries were indeed made by the ld AO or not in assessment proceedings. In that scenario

Income Tax Officer, Ward-1, Ichalkaranji vs. Sanjay Ghodawat Buildcon LLP, Chipri

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

ITA 1337/PUN/2024[2015-16]Status: DisposedITAT Pune21 Apr 2025AY 2015-16

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.1337/Pun/2024 Assessment Year : 2015-16

For Appellant: Shri Arvind DesaiFor Respondent: Shri Prashanth GS

Section 142(1)Section 144Section 263Section 40Section 46A(3)Section 57

after giving the effect to the Direction, no loss to the revenue results, the order cannot be the subject matter of the revision u/s 263 of the Income Tax Act, 1967 as it is not prejudicial to the interest of the revenue. Hence, other grounds do not need adjudication

Hariram Hospital, Alwar vs. PCIT, Alwar

In the result, the appeal of the assessee is allowed

ITA 1535/JPR/2024[2019-20]Status: DisposedITAT Jaipur17 Apr 2025AY 2019-20

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI, AM आयकरअपीलसं./ITA No. 1535/JPR/2024 निर्धारणवर्ष / Assessment Year: 2019-20 Hariram Hospital Bye Pass Road Hariram Hospital Bhiwadi, Alwar – 310 019 (Raj) बनाम Vs. The Pr.CIT (Central) Jaipur प्रत्यर्थी / Respondent स्थायीलेखा सं. / जीआईआरसं./PAN/GIR No.: AAFFH 5746 M अपीलार्थी / Appellant निर्धारिती की ओरसे / Assesseeby : Shri Himanshu Goyal, CA राजस्व की ओरसे /Revenue by: Mrs. Alka Gautam, CIT-DR सुनवाई की तारीख / Da

For Appellant: Shri Himanshu Goyal, CAFor Respondent: Mrs. Alka Gautam, CIT-DR

Section 143(3)Section 263

Revenue authorities. The PCIT has failed to discharge his burden by presenting any credible evidence to support their claim. 5. That the revision u/s 263 is prejudicial to the interest of the assessee as it unnecessarily subjects them to further scrutiny without any substantive basis. The prolonged assessment process adversely ... action 13 HARIRAM HOSPITAL, ALWAR VS PCIT (CENTRAL), JAIPUR now initiated is just a change of opinion hence cannot be subject to the revision u/s 263 of the Income Tax Act 1961 The A.R further placed reliance on the decisions as under 1 SMT LATA PHULWANI CIO RAMANAND GOYAL

Indo Pacific Finlease Ltd, Chandigarh vs. PCIT- Chandigarh 1, Chandigarh

In the result, both the appeals are filed by the

ITA 449/CHANDI/2024[2015-16]Status: DisposedITAT Chandigarh16 Apr 2025AY 2015-16

Bench: Shrilaliet Kumar & Shri Krinwant Sahayआयकर अपील सं . / I.T.A. Nos.448 & 449/Chd/2024 निर्धारणवर्ष / Assessment Years: 2014-15 & 2015-16

For Appellant: Sh. Ashok Goel, C.AFor Respondent: Sh.Rohit Sharma, CIT-D.R

Section 147Section 148Section 203(1)Section 263

inter alia for this reason that the reassessment order passed u/s 147 r.w.s 144 r.w.s 1448 dated 26.03.2022 which is sought to be revised u/s 263 itself was invalid inter alia on various grounds as mentioned below and thus proceedings initiated u/s 263 against the invalid reassessment order is clearly ... verified by the Assessing Officer at the very inception of the consequential actions directed to be carried out through this order of revision u/s 263 of the Act. The other legal positions stated as applicable by the assessee including the arriving at, the satisfaction and/or_reason to believe, by the Assessing

Indo Pacific Finlease Ltd, Chandigarh vs. PCIT Chandigarh 1, Chandigarh

In the result, both the appeals are filed by the

ITA 448/CHANDI/2024[2014-15]Status: DisposedITAT Chandigarh16 Apr 2025AY 2014-15

Bench: Shrilaliet Kumar & Shri Krinwant Sahayआयकर अपील सं . / I.T.A. Nos.448 & 449/Chd/2024 निर्धारणवर्ष / Assessment Years: 2014-15 & 2015-16 Vs Pcitchandigarh 1, Chandigarh Indo Pacific Finlease Ltd., Sco-98-99, Sector 34 Sub City Centre, Chandigarh 160002 स्थायीलेखासं./Panno. Aaaci2176E अपीलार्थी/Appellant प्रत्यर्थी/Respondent Assessee By : Sh. Ashok Goel, C.A. Revenue By : Sh.Rohit Sharma, Cit-D.R. Date Of Hearing :19.03.2025 Date Of Pronouncement ;16/04/2025 Physical Hearing Order Per Laliet Kumar, J.M.: Both The Appeals Are Being Filed By The Assessee, Feeling Aggrieved By The Order Passed By The Ld. Pr. Commissioner Of Income Tax, Chandigarh-1 Dated 28.03.2024& 23.03.2024 U/S 263 For The Assessment Years: 2014-15& 2015-16. 2. The Assessee Has Raised The Common Grounds Of Appeal In Ita Nos.448 & 449/Chd/2024 As Under:

For Appellant: Sh. Ashok Goel, C.AFor Respondent: Sh.Rohit Sharma, CIT-D.R

Section 147Section 148Section 203(1)Section 263

inter alia for this reason that the reassessment order passed u/s 147 r.w.s 144 r.w.s 1448 dated 26.03.2022 which is sought to be revised u/s 263 itself was invalid inter alia on various grounds as mentioned below and thus proceedings initiated u/s 263 against the invalid reassessment order is clearly ... inter alia for this reason that the reassessment order passed u/s 147 r.w.s 144 r.w.s 1448 dated 26.03.2022 which is sought to be revised u/s 263 itself was invalid inter alia on various grounds as mentioned below and thus proceedings initiated u/s 263 against the invalid reassessment order is clearly

Dy. Commissioner of Income Tax, Cir 1(3)(1), Income Tax Department vs. Skate Trades and Agencies Private Limited, Raichur Street Mumbai

In the result, the appeal of the assessee is dismissed

ITA 1663/MUM/2024[2017-18]Status: DisposedITAT Mumbai16 Apr 2025AY 2017-18

Bench: Shri Narendra Kumar Billaiyashri Sandeep Singh Karhaildy. Commissioner Of Income Tax, Circle-1(3)(1), Room No.535, Aayakar Bhawan, M.K. Road, Churchgate ............... Appellant Mumbai - 400020

For Appellant: NoneFor Respondent: Shri Bhangepatil Pushkaraj, Sr.DR

Section 115BSection 142(1)Section 143(2)Section 250

where the AO has conducted enquiry during assessment proceeding but not discussed the outcome in assessment-order, the PCIT cannot make revision u/s 263 to substitute his own view. We certainly agree with such views but the facts of present appeal are different and do not warrant application of those

Clix Capital Services Private Limited, Delhi vs. Principal Commissioner of Income Tax, Delhi-1, Delhi

In the result the appeal of the assessee is allowed

ITA 2732/DEL/2024[2018-19]Status: DisposedITAT Delhi15 Apr 2025AY 2018-19

For Appellant: Shri Ajay Vohra, Sr. AdvFor Respondent: Shri Sanjay Kumar Bharati, CIT DR

Section 139(1)Section 143(3)Section 144BSection 263Section 37

Dakshayani Horticulture Private Limited, Hyderabad vs. ACIT., Central Circle-2(4), Hyderabad

In the result, ITA.No.1333/Hyd

ITA 1333/HYD/2024[2019-20]Status: DisposedITAT Hyderabad09 Apr 2025AY 2019-20

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

For Respondent: Shri B. Bala Krishna, CIT-DR

Section 1Section 132Section 143(2)Section 153CSection 153DSection 263

provisions of section 263 of the Act to revise the assessment order passed u/s 153C of the Act, though the powers of revision u/s 263 do not extend to such assessment order passed with the prior approval of the JCIT u/s 153D of the Act. 3. The Ld. Principal ... 153D of the Act though such approval does not constitute an order passed under the Act which could be a subject matter of revision u/s 263 of the Act. 4. The order of revision u/s 263 is without jurisdiction and unsustainable in law, as the base assessment order passed u/s

Satyanarayana Reddy Manne, Hyderabad vs. ACIT., Central Circle-2(4), Hyderabad

In the result, appeal of the Assessee is allowed

ITA 1332/HYD/2024[2018-19]Status: DisposedITAT Hyderabad09 Apr 2025AY 2018-19

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

For Appellant: CA MV Prasad and Shri KS Rajendra KumarFor Respondent: Shri B. Bala Krishna, CIT-DR

Section 132Section 142(1)Section 143(1)Section 143(2)Section 143(3)Section 153ASection 153CSection 153DSection 263

provisions of section 263 of the Act to revise the assessment order passed u/s 153A of the Act, though the powers of revision u/s 263 do not extend to such assessment order passed with the prior approval of the JCIT u/s 153D of the Act. 3. The Ld. Principal ... 153D of the Act though such approval does not constitute an order passed under the Act which could be a subject matter of revision u/s 263 of the Act 4. The order u/s 263 which sought to revise the assessment order passed u/s 153A is without jurisdiction and unsustainable

Adrija Farms Private Limited, Hyderabad vs. ACIT., Central Circle-2(4), Hyderabad

In the result, ITA.No.1333/Hyd

ITA 1331/HYD/2024[2019-20]Status: DisposedITAT Hyderabad09 Apr 2025AY 2019-20

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

For Respondent: Shri B. Bala Krishna, CIT-DR

Section 1Section 132Section 143(2)Section 153CSection 153DSection 263