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“erroneous and prejudicial”

Rectification & RevisionSection 263Section 2633,136 judgments

SHALBY LTD.,AHMEDABAD vs. THE PCIT, AHMEDABAD-3, AHMEDABAD

In the result, the appeal of the assessee is allowed

ITA 1227/AHD/2025[2020-21]Status: DisposedITAT Ahmedabad26 Mar 2026AY 2020-21

Bench: Ms Suchitra Kamble & Shri Narendra Prasad Sinhaassessment Years: 2020-21

Section 132Section 143(3)Section 14ASection 263Section 80G

respect of donation made to this party vis-à-vis the MAT income, the order of the AO was held to be erroneous and prejudicial to the interest of the revenue. 2.1 Another issue in respect of which the order of the AO was held to the erroneous and prejudicial ... setting aside the Assessment Order passed us. 143(3) rows 144B of the IT. Act. 1961 did 27.092022 which is neither erroneous nor prejudicial to the interest of the Revenue 2 The Learned Pr Commissioner of Income Tax, Ahmedabad-3 has erred in passing an order

NEERAJ ,FARIDABAD vs. PR, CIT , FARIDABAD

In the result, appeal filed by the assessee stands allowed

ITA 939/DEL/2025[2012-13]Status: DisposedITAT Delhi20 Mar 2026AY 2012-13

Bench: Shri Yogesh Kumar U.S. & Shri Amitabh Shukla, Accountnat Member

Section 144Section 144BSection 147Section 148Section 263Section 44ASection 68Section 69A

Income Tax Act, 1961 (the Act) holding the order passed by the Income Tax Officer, Ward - 2(1), Faridabad to be erroneous and prejudicial to the interest of Revenue and directing the Assessing Officer to make a fresh assessment denovo, without appreciating the fact that: 1.1 The return of income ... Meanwhile, the PCIT, Faridabad, invoked his revisionary powers under section 263 and through order dated 23/03/2022 held that the impugned assessment order was erroneous and prejudicial to the interest of revenue and directed the Assessing Officer to pass a fresh assessment order and to recompute the assessee's income after

NEERAJ,FARIDABAD vs. ITO,WARD-2(1), FARIDABAD

In the result, appeal filed by the assessee stands allowed

ITA 938/DEL/2025[2012-13]Status: DisposedITAT Delhi20 Mar 2026AY 2012-13

Bench: Shri Yogesh Kumar U.S. & Shri Amitabh Shukla, Accountnat Member

Section 144Section 144BSection 147Section 148Section 263Section 44ASection 68Section 69A

Income Tax Act, 1961 (the Act) holding the order passed by the Income Tax Officer, Ward - 2(1), Faridabad to be erroneous and prejudicial to the interest of Revenue and directing the Assessing Officer to make a fresh assessment denovo, without appreciating the fact that: 1.1 The return of income ... Meanwhile, the PCIT, Faridabad, invoked his revisionary powers under section 263 and through order dated 23/03/2022 held that the impugned assessment order was erroneous and prejudicial to the interest of revenue and directed the Assessing Officer to pass a fresh assessment order and to recompute the assessee's income after

RELIANCE INDUSTRIAL INFRASTRUCTURE LIMITED ,MUMBAI vs. PRINCIPAL COMMISSIONER OF INCOME TAX -3, MUBMAI

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

ITA 3751/MUM/2025[2020-21]Status: DisposedITAT Mumbai18 Mar 2026AY 2020-21

Bench: Shri Vikram Singh Yadav, Am & Ms. Kavitha Rajagopal, Jm M/S. Reliance Industrial Principal Commissioner Of Income Infrastructure Limited, Tax – 3, 5Th Floor, Nkm International House, Aayakar Bhavan, Vs. 178 Backbay Reclamation Marine Maharshi Karve Road, Lines Mumbai – 400 020 Mumbai – 400 020 Pan:Aaacr7637P (Appellant) : (Respondent)

For Respondent: Shri Umashankar Prasad, CIT-DR
Section 143(2)Section 143(3)Section 14ASection 263Section 37(1)Section 80G

contended that the impugned order of Ld. PCIT does not satisfy the twin condition where the assessment order has to be erroneous and prejudicial to the interest of the Revenue. The Ld. AR relied on a catena of decisions in support of the assessee’s contention. 6. The Learned Departmental ... conduct any enquiry with regard to the assessee’s claim of deduction which itself tantamounts to holding that the assessment order is erroneous and prejudicial to the interest of the Revenue. Further, the Ld. DR contended that the CSR expenditure is not a voluntary donation given by the assessee

AMAZON SMART COMMERCE SOLUTIONS PRIVATE LIMITED,DELHI vs. PRINCIPAL COMMISSIONER OF INCOME TAX, DELHI-1, DELHI

In the result, grounds raised by the assessee are dismissed

ITA 3533/DEL/2025[2021-22]Status: DisposedITAT Delhi18 Mar 2026AY 2021-22
Section 143(1)Section 143(3)Section 263Section 40A(2)

examined by the Principal CIT, Delhi–1, and it was observed that, prima facie, the AO had passed the order which is both erroneous and prejudicial to the interest of the revenue on several counts. Accordingly, the learned PCIT issued a show-cause notice under section ... impugned order and rejected the issues raised by the assessee. With regard to the issue of the assessment order being erroneous and prejudicial to the interest of the Revenue, the learned PCIT dealt with each issue elaborately in the impugned order and observed that the Assessing Officer had raised queries

DAVINDER KUMAR MAGO,PUNJABI BAGH vs. DCIT/ACIT CENTRAL CIRCLE, DDN, DEHRADUN

In the result appeal of the assessee is allowed

ITA 17/DDN/2026[2019-20]Status: DisposedITAT Dehradun12 Mar 2026AY 2019-20

Bench: Shri Mahavir Singh & Shri Manish Agarwal[Assessment Year : 2019-20] Davinder Kumar Mago Vs Dcit/Acit 12/1, Punjabi Bagh, Central Circle, External Punjabi Bagh, Dehradun New Delhi-110026 Uttarakhand Pan-Ajhpm9802A Appellant Respondent Appellant By Shri Ajay Wadhwa, Adv. (Vc) Respondent By Ms. Poonam Sharma, Cit Dr Date Of Hearing 10.03.2026 Date Of Pronouncement 12.03.2026 Order Per Manish Agarwal, Am : This Appeal Filed By The Assessee Against The Order By Pr.Cit (Central), Kanpur At Meerut Passed U/S 263 Of The Income Tax Act, 1861 (“The Act”) Dated 08.01.2026 Arising Out Of The Order Passed U/S 143(3) R.W.S. 147 Of The Act.

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

under Section 263 of the Act, but, he must, at least indicate in his order how the order of the Assessing Officer is erroneous and prejudicial to the interest of the Revenue. The revisional power under Section 263 of the Act is not meant to be exercised to correct every ... error of fact, but the error must be of such a nature that it is erroneous and prejudicial to the interest of the Revenue. The PCIT, in revisional proceedings under Section 263 of the Act, has no jurisdiction to set aside the order of assessment merely to conduct another Investigation

SHEELA GOYAL,CHANDIGARH vs. PR. COMMISSIONER OF INCOME TAX, CHANDIGARH

In the result, appeal of the Assessee is allowed

ITA 690/CHANDI/2025[2016-17]Status: DisposedITAT Chandigarh12 Mar 2026AY 2016-17

Bench: Shri Laliet Kumar & Shri Krinwant Sahayआयकर अपील सं./ Ita No. 690/Chd/2025 "नधा"रण वष" / Assessment Year : 2016-17 Sheela Goyal, The Pcit, 3180, Sector 28-D, बनाम Chandigarh Chandigarh Vs. "थायी लेखा सं./ Pan No: Aaypg0407H अपीलाथ"/Appellant ""यथ"/Respondent ( Hybrid Hearing ) "नधा"रती क" ओर से/Assessee By : Sh. Manoj Kumar, Ca राज"व क" ओर से/ Revenue By : Sh. Rajat Kumar Kureel, Cit Dr (Virtual Mode) सुनवाई क" तार"ख/Date Of Hearing : 15.01.2026 उदघोषणा क" तार"ख/Date Of Pronouncement : 12.03.2026

For Appellant: Sh. Manoj Kumar, CAFor Respondent: Sh. Rajat Kumar Kureel, CIT DR
Section 143(2)Section 147Section 148Section 263

income of the assessee as per the applicable provisions. The order passed u/s 147 of the Act, dated 31.03.2023, thus appears to be erroneous, and prejudicial to the interest of revenue in terms of provisions of section 263 of the Act including Explanation 2 inserted by Finance ... reply to the Ld. PCIT Chandigarh-1. The Ld. PCIT’s findings that the order passed by the Assessing Officer was erroneous and prejudicial to the interest of Revenue, is therefore, not appropriate and thus cannot be sustained. Accordingly, the issuance of notice and order passed

SRI GURU RAMALINGESHWARA SOUHARDA PATTINA SAHAKARI NIYAMITHA ,MASKI vs. PR. COMMISSIONER OF INCOME TAX , HUBLI

In the result, the appeal of the assessee is hereby allowed

ITA 1174/BANG/2025[2020-21]Status: DisposedITAT Bangalore12 Mar 2026AY 2020-21

Bench: Shri Waseem Ahmed & Shri Soundararajan Kassessment Year: 2020-21

For Appellant: Shri Ravishankar, AdvocateFor Respondent: Shri Muthu Shankar, JCIT (DR)
Section 143(3)Section 263Section 56Section 80PSection 80P(2)(a)Section 80P(2)(d)

view that the AO failed to properly examine this issue and allowed the deduction without verification. Therefore, the assessment order was considered erroneous and prejudicial to the interests of the Revenue under section 263 of the Act. 3.6 In response to the notice issued under section ... this interest income. As per Explanation 2 to section 263 of the Act, an order passed without proper enquiry or verification is considered erroneous and prejudicial to the interests of the Revenue. 5.3 Therefore, the PCIT held that the assessment order dated 06.09.2022 was passed without proper examination

SWD INDUSTRIES,MUMBAI vs. PCIT (CENTRAL), MUMBAI-1, MUMBAI

In the result, all the appeals filed by the assessee for the respective assessment years are allowed, and the impugned orders passed by the learned PCIT under section 263 of the Act are set aside

ITA 9012/MUM/2025[2020-2021]Status: DisposedITAT Mumbai12 Mar 2026AY 2020-2021

Bench: Shri Saktijit Dey & Shri Makarand Vasant Mahadeokar1. Ita No. 9007/Mum/2025 (Assessment Year: 2014-15) 2. Ita No. 9008/Mum/2025 (Assessment Year: 2015-16) 3. Ita No. 9009/Mum/2025 (Assessment Year: 2016-17) 4. Ita No. 9010/Mum/2025 (Assessment Year: 2017-18) 5. Ita No. 9011/Mum/2025 (Assessment Year: 2019-20) & 6. Ita No. 9012/Mum/2025 (Assessment Year: 2020-21) Swd Industries, Pcit (Central), 1402, South Tower 25, Mumbai-1, South Prabhadevi, Vs. R. No. 1001, 10Th Mumbai-400 025 Floor, Pratistha Bhavan, Old Cgo Annexe, Maharshi Karve Road, Mumbai-400 020 Pan/Gir No. Aaofs8319L (Applicant) (Respondent) Assessee By Shri Salil Kapoor A/W Shri Sumit Lalchandani, Shri Shivam Yadav, Shri Shri Vinod Gupta, Ld. Ars Revenue By Shri Vivek Perampurna, Ld. Dr Date Of Hearing 10.03.2026 Date Of Pronouncement 12.03.2026

Section 132Section 143(3)Section 153CSection 153DSection 263

That the PCIT, Mumbai has erred in invoking Explanation 2 to section 263 of the Act by holding the assessment order to be erroneous and prejudicial to the interests of the Revenue, despite the fact that the Assessing Officer had completed the assessment after due and comprehensive enquiry and verification ... Group), statement recorded and after mandatory approval u/s 153D of the Act from Addl CIT and therefore, to hold such an order as erroneous and prejudicial to the interest of the revenue is unjustified and bad in law. 9. The PCIT, Mumbai in the impugned order as failed to point

SWD INDUSTRIES,MUMBAI vs. PCIT (CENTRAL), MUMBAI-1, MUMBAI

In the result, all the appeals filed by the assessee for the respective assessment years are allowed, and the impugned orders passed by the learned PCIT under section 263 of the Act are set aside

ITA 9011/MUM/2025[2019-2020]Status: DisposedITAT Mumbai12 Mar 2026AY 2019-2020

Bench: Shri Saktijit Dey & Shri Makarand Vasant Mahadeokar1. Ita No. 9007/Mum/2025 (Assessment Year: 2014-15) 2. Ita No. 9008/Mum/2025 (Assessment Year: 2015-16) 3. Ita No. 9009/Mum/2025 (Assessment Year: 2016-17) 4. Ita No. 9010/Mum/2025 (Assessment Year: 2017-18) 5. Ita No. 9011/Mum/2025 (Assessment Year: 2019-20) & 6. Ita No. 9012/Mum/2025 (Assessment Year: 2020-21) Swd Industries, Pcit (Central), 1402, South Tower 25, Mumbai-1, South Prabhadevi, Vs. R. No. 1001, 10Th Mumbai-400 025 Floor, Pratistha Bhavan, Old Cgo Annexe, Maharshi Karve Road, Mumbai-400 020 Pan/Gir No. Aaofs8319L (Applicant) (Respondent) Assessee By Shri Salil Kapoor A/W Shri Sumit Lalchandani, Shri Shivam Yadav, Shri Shri Vinod Gupta, Ld. Ars Revenue By Shri Vivek Perampurna, Ld. Dr Date Of Hearing 10.03.2026 Date Of Pronouncement 12.03.2026

Section 132Section 143(3)Section 153CSection 153DSection 263

That the PCIT, Mumbai has erred in invoking Explanation 2 to section 263 of the Act by holding the assessment order to be erroneous and prejudicial to the interests of the Revenue, despite the fact that the Assessing Officer had completed the assessment after due and comprehensive enquiry and verification ... Group), statement recorded and after mandatory approval u/s 153D of the Act from Addl CIT and therefore, to hold such an order as erroneous and prejudicial to the interest of the revenue is unjustified and bad in law. 9. The PCIT, Mumbai in the impugned order as failed to point

SWD INDUSTRIES,MUMBAI vs. PCIT (CENTRAL), MUMBAI-1, MUMBAI

In the result, all the appeals filed by the assessee for the respective assessment years are allowed, and the impugned orders passed by the learned PCIT under section 263 of the Act are set aside

ITA 9010/MUM/2025[2017-2018]Status: DisposedITAT Mumbai12 Mar 2026AY 2017-2018

Bench: Shri Saktijit Dey & Shri Makarand Vasant Mahadeokar1. Ita No. 9007/Mum/2025 (Assessment Year: 2014-15) 2. Ita No. 9008/Mum/2025 (Assessment Year: 2015-16) 3. Ita No. 9009/Mum/2025 (Assessment Year: 2016-17) 4. Ita No. 9010/Mum/2025 (Assessment Year: 2017-18) 5. Ita No. 9011/Mum/2025 (Assessment Year: 2019-20) & 6. Ita No. 9012/Mum/2025 (Assessment Year: 2020-21) Swd Industries, Pcit (Central), 1402, South Tower 25, Mumbai-1, South Prabhadevi, Vs. R. No. 1001, 10Th Mumbai-400 025 Floor, Pratistha Bhavan, Old Cgo Annexe, Maharshi Karve Road, Mumbai-400 020 Pan/Gir No. Aaofs8319L (Applicant) (Respondent) Assessee By Shri Salil Kapoor A/W Shri Sumit Lalchandani, Shri Shivam Yadav, Shri Shri Vinod Gupta, Ld. Ars Revenue By Shri Vivek Perampurna, Ld. Dr Date Of Hearing 10.03.2026 Date Of Pronouncement 12.03.2026

Section 132Section 143(3)Section 153CSection 153DSection 263

That the PCIT, Mumbai has erred in invoking Explanation 2 to section 263 of the Act by holding the assessment order to be erroneous and prejudicial to the interests of the Revenue, despite the fact that the Assessing Officer had completed the assessment after due and comprehensive enquiry and verification ... Group), statement recorded and after mandatory approval u/s 153D of the Act from Addl CIT and therefore, to hold such an order as erroneous and prejudicial to the interest of the revenue is unjustified and bad in law. 9. The PCIT, Mumbai in the impugned order as failed to point

SWD INDUSTRIES,MUMBAI vs. PCIT (CENTRAL), MUMBAI-1, MUMBAI

In the result, all the appeals filed by the assessee for the respective assessment years are allowed, and the impugned orders passed by the learned PCIT under section 263 of the Act are set aside

ITA 9009/MUM/2025[2016-2017]Status: DisposedITAT Mumbai12 Mar 2026AY 2016-2017

Bench: Shri Saktijit Dey & Shri Makarand Vasant Mahadeokar1. Ita No. 9007/Mum/2025 (Assessment Year: 2014-15) 2. Ita No. 9008/Mum/2025 (Assessment Year: 2015-16) 3. Ita No. 9009/Mum/2025 (Assessment Year: 2016-17) 4. Ita No. 9010/Mum/2025 (Assessment Year: 2017-18) 5. Ita No. 9011/Mum/2025 (Assessment Year: 2019-20) & 6. Ita No. 9012/Mum/2025 (Assessment Year: 2020-21) Swd Industries, Pcit (Central), 1402, South Tower 25, Mumbai-1, South Prabhadevi, Vs. R. No. 1001, 10Th Mumbai-400 025 Floor, Pratistha Bhavan, Old Cgo Annexe, Maharshi Karve Road, Mumbai-400 020 Pan/Gir No. Aaofs8319L (Applicant) (Respondent) Assessee By Shri Salil Kapoor A/W Shri Sumit Lalchandani, Shri Shivam Yadav, Shri Shri Vinod Gupta, Ld. Ars Revenue By Shri Vivek Perampurna, Ld. Dr Date Of Hearing 10.03.2026 Date Of Pronouncement 12.03.2026

Section 132Section 143(3)Section 153CSection 153DSection 263

That the PCIT, Mumbai has erred in invoking Explanation 2 to section 263 of the Act by holding the assessment order to be erroneous and prejudicial to the interests of the Revenue, despite the fact that the Assessing Officer had completed the assessment after due and comprehensive enquiry and verification ... Group), statement recorded and after mandatory approval u/s 153D of the Act from Addl CIT and therefore, to hold such an order as erroneous and prejudicial to the interest of the revenue is unjustified and bad in law. 9. The PCIT, Mumbai in the impugned order as failed to point

SWD INDUSTRIES,MUMBAI vs. PCIT (CENTRAL), MUMBAI-1, MUMBAI

In the result, all the appeals filed by the assessee for the respective assessment years are allowed, and the impugned orders passed by the learned PCIT under section 263 of the Act are set aside

ITA 9008/MUM/2025[2015-2016]Status: DisposedITAT Mumbai12 Mar 2026AY 2015-2016

Bench: Shri Saktijit Dey & Shri Makarand Vasant Mahadeokar1. Ita No. 9007/Mum/2025 (Assessment Year: 2014-15) 2. Ita No. 9008/Mum/2025 (Assessment Year: 2015-16) 3. Ita No. 9009/Mum/2025 (Assessment Year: 2016-17) 4. Ita No. 9010/Mum/2025 (Assessment Year: 2017-18) 5. Ita No. 9011/Mum/2025 (Assessment Year: 2019-20) & 6. Ita No. 9012/Mum/2025 (Assessment Year: 2020-21) Swd Industries, Pcit (Central), 1402, South Tower 25, Mumbai-1, South Prabhadevi, Vs. R. No. 1001, 10Th Mumbai-400 025 Floor, Pratistha Bhavan, Old Cgo Annexe, Maharshi Karve Road, Mumbai-400 020 Pan/Gir No. Aaofs8319L (Applicant) (Respondent) Assessee By Shri Salil Kapoor A/W Shri Sumit Lalchandani, Shri Shivam Yadav, Shri Shri Vinod Gupta, Ld. Ars Revenue By Shri Vivek Perampurna, Ld. Dr Date Of Hearing 10.03.2026 Date Of Pronouncement 12.03.2026

Section 132Section 143(3)Section 153CSection 153DSection 263

That the PCIT, Mumbai has erred in invoking Explanation 2 to section 263 of the Act by holding the assessment order to be erroneous and prejudicial to the interests of the Revenue, despite the fact that the Assessing Officer had completed the assessment after due and comprehensive enquiry and verification ... Group), statement recorded and after mandatory approval u/s 153D of the Act from Addl CIT and therefore, to hold such an order as erroneous and prejudicial to the interest of the revenue is unjustified and bad in law. 9. The PCIT, Mumbai in the impugned order as failed to point

SWD INDUSTRIES,MUMBAI vs. PCIT (CENTRAL), MUMBAI-1, MUMBAI

In the result, all the appeals filed by the assessee for the respective assessment years are allowed, and the impugned orders passed by the learned PCIT under section 263 of the Act are set aside

ITA 9007/MUM/2025[2014-2015]Status: DisposedITAT Mumbai12 Mar 2026AY 2014-2015

Bench: Shri Saktijit Dey & Shri Makarand Vasant Mahadeokar1. Ita No. 9007/Mum/2025 (Assessment Year: 2014-15) 2. Ita No. 9008/Mum/2025 (Assessment Year: 2015-16) 3. Ita No. 9009/Mum/2025 (Assessment Year: 2016-17) 4. Ita No. 9010/Mum/2025 (Assessment Year: 2017-18) 5. Ita No. 9011/Mum/2025 (Assessment Year: 2019-20) & 6. Ita No. 9012/Mum/2025 (Assessment Year: 2020-21) Swd Industries, Pcit (Central), 1402, South Tower 25, Mumbai-1, South Prabhadevi, Vs. R. No. 1001, 10Th Mumbai-400 025 Floor, Pratistha Bhavan, Old Cgo Annexe, Maharshi Karve Road, Mumbai-400 020 Pan/Gir No. Aaofs8319L (Applicant) (Respondent) Assessee By Shri Salil Kapoor A/W Shri Sumit Lalchandani, Shri Shivam Yadav, Shri Shri Vinod Gupta, Ld. Ars Revenue By Shri Vivek Perampurna, Ld. Dr Date Of Hearing 10.03.2026 Date Of Pronouncement 12.03.2026

Section 132Section 143(3)Section 153CSection 153DSection 263

That the PCIT, Mumbai has erred in invoking Explanation 2 to section 263 of the Act by holding the assessment order to be erroneous and prejudicial to the interests of the Revenue, despite the fact that the Assessing Officer had completed the assessment after due and comprehensive enquiry and verification ... Group), statement recorded and after mandatory approval u/s 153D of the Act from Addl CIT and therefore, to hold such an order as erroneous and prejudicial to the interest of the revenue is unjustified and bad in law. 9. The PCIT, Mumbai in the impugned order as failed to point

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

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

ITA 216/RJT/2024[2018-19]Status: DisposedITAT Rajkot11 Mar 2026AY 2018-19

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

For Appellant: Shri Hardik Vora, ARFor Respondent: Shri Sanjay Punglia, CIT. DR
Section 143(3)Section 263Section 68

Claymine Microns LLP vs. PCIT Order of AY 2018-19 passed u/s 143(3) of the Act dated 23.04.2021 is neither erroneous nor prejudicial to the interest of the revenue. 3. The appellant further reserves it’s right to add, alter, amend or modify any of the aforesaid grounds before ... considering the reply of the assessee, the assessing officer has framed the assessment order, therefore, order passed by the assessing officer is neither erroneous nor prejudicial to the interest of the Revenue. Hence, the jurisdiction exercised by the Ld.PCIT u/s.263 of the Act should be quashed. 11. On the other

MICROTEK INFRASTRUTURES PRIVATE LIMITED,DELHI vs. PCIT, NEW DELHI

In the result, the appeal of the assessee is dismissed

ITA 3112/DEL/2025[2020-21]Status: DisposedITAT Delhi11 Mar 2026AY 2020-21

Bench: Shri Anubhav Sharma& Shri Amitabh Shukla[Assessment Year:2020-21]

Section 133(6)Section 142(1)Section 143(3)Section 263Section 37(1)Section 68

reproduced hereunder:- “7 In view of the above discussion, I find that the assessment order passed by the AO dated. 26.09.2022 is erroneous and prejudicial to the interest of revenue. 8 In this regard, reliance is also place on the following decisions of Hon’ble Supreme Court ... been passed without making necessary examination/verification/enquiries on the issue discussed above and therefore, I hold the Assessment Order as erroneous and prejudicial to the interest of the revenue. Accordingly, the said Assessment Order is hereby set aside to the file of the Assessing Officer on the above issues. Needless

ACIT, GNR CIRCLE, GNR, GANDHINAGAR vs. SAHAJANAND LASER TECHNOLOGY LIMITED, GANDHINAGAR

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

ITA 94/AHD/2024[2014-15]Status: DisposedITAT Ahmedabad09 Mar 2026AY 2014-15

Bench: DR. BRR Kumar (Vice President), Shri T. R. Senthil Kumar (Judicial Member)

Section 115JSection 143Section 143(3)

provisions at Rs.7,38,27,158/= and under book profit u/s.115JB at Rs.15,76,68,533/=. This assessment order was found to be erroneous and prejudicial to the interest of Revenue, therefore Ld.PCIT passed revision order dated 13-02-2019 with direction to the AO to make proper inquiry

SAHAJANAND LASER TECHNOLOGY LIMITED,GANDHINAGAR vs. THE ASSTT.CIT., CIRCLE-4(1)(1), AHMEDABAD

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

ITA 839/AHD/2023[2014-15]Status: DisposedITAT Ahmedabad09 Mar 2026AY 2014-15

Bench: DR. BRR Kumar (Vice President), Shri T. R. Senthil Kumar (Judicial Member)

Section 115JSection 143Section 143(3)

provisions at Rs.7,38,27,158/= and under book profit u/s.115JB at Rs.15,76,68,533/=. This assessment order was found to be erroneous and prejudicial to the interest of Revenue, therefore Ld.PCIT passed revision order dated 13-02-2019 with direction to the AO to make proper inquiry

DEBPARA TEA CO. LTD., ,KOLKATA vs. PCIT, , SILIGURI

In the result, the appeal of the assessee is allowed

ITA 983/KOL/2025[2020-2021]Status: DisposedITAT Kolkata06 Mar 2026AY 2020-2021

Bench: SHRI RAJESH KUMAR (Accountant Member)

Section 143(3)Section 263Section 8

assessment order, the AO determined loss of Rs. 55,85,277/- and therefore, the assessment order framed by the AO is erroneous and prejudicial to the interest of the revenue. Accordingly, show cause notice issued to the assessee u/s 263 of the Act. The assessee replied by specifically submitting that ... without understanding the factual legal aspect of the matter is wrong. In our considered view the order passed by the AO is neither erroneous nor prejudicial to the interest of revenue. The case of the assessee is squarely covered by the decision of Hon’ble Supreme Court in the case

CISCO COMMERCE INDIA PRIVATE LIMITED,BANGALORE vs. PRINCIPAL COMMISSIONER OF INCOME TAX, PCIT, BENGALURU-2, BANGALORE

In the result, the appeal by the assessee is dismissed

ITA 1235/BANG/2025[2021-22]Status: DisposedITAT Bangalore05 Mar 2026AY 2021-22

Bench: Shri Prashant Maharishi & Shri Soundararajan K.Assessment Year: 2021-22

For Appellant: Shri Nageshwar Rao, AdvocateFor Respondent: Smt. N. Hemalatha, CIT(DR)(ITAT), Bengaluru
Section 143(3)Section 154Section 194JSection 263Section 40

dated 29.3.2025. The PCIT found that the Page 2 of 24 assessment order passed under Section 143(3) read with 144B was erroneous and prejudicial to Revenue because the issue of 'refund liabilities' was not properly examined by the Assessing Officer. 2. The assessee is dissatisfied with the revisionary order ... made which is subject matter of appeal. 5. Perfunctory and routine conclusions in Impugned order that Assessment order dated December 26,2022 is erroneous and/or prejudicial to revenue is without valid basis, ignores material filed/ explanations offered. Revisionary proceedings are Page 3 of 24 unlawful and illegal and deserve

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