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“erroneous and prejudicial”

Rectification & RevisionSection 263Section 2633,136 judgments

The decision most relied on for erroneous and prejudicial is Malabar Industrial Co. Ltd. v. CIT (243 ITR 83), cited in 2,943 judgments on BharatTax.

Leading authorities on erroneous and prejudicial

Malabar Industrial Co. Ltd. v. CIT
243 ITR 83 · 2000 · Supreme Court
2,943
citing judgments

For revision under Section 263, the Assessing Officer's order must be both erroneous and prejudicial to the interests of the revenue; if either condition is not met, the revisionary jurisdiction cannot be invoked. An order is not erroneous merely because the Assessing Officer did not record the details of enquiries conducted, provided due enquiries were made.

CIT v. Max India Ltd.
295 ITR 282 · 2007 · Supreme Court
1,162
citing judgments

Under Section 263, an assessment order is not erroneous and prejudicial to the interest of the revenue merely because the Principal Commissioner disagrees with the Assessing Officer's (AO) view, particularly if the AO has adopted one of two permissible views in law, unless that view is completely unsustainable. If due inquiries were made, the AO's order does not become erroneous solely because the fact of inquiries was not recorded.

CIT v. Gabriel India Ltd.
203 ITR 108 · 1993 · High Court
990
citing judgments

The Commissioner cannot revise an assessment order under Section 263 merely because they hold a different opinion or believe a deeper inquiry was warranted if the Assessing Officer has applied their mind and conducted some inquiry. Revision under Section 263 is permissible only in cases of a complete lack of inquiry or non-application of mind by the Assessing Officer, not for merely inadequate inquiry.

CIT v. Sunbeam Auto Ltd.
332 ITR 167 · 2011 · High Court
897
citing judgments

The Commissioner cannot revise an assessment under Section 263 merely because the assessment order does not explicitly reflect an inquiry, or because the Commissioner holds a different opinion. An inquiry, even if considered inadequate, or an assessment based on a plausible view by the Assessing Officer after due examination, does not automatically make the order erroneous or prejudicial to the interests of the revenue.

Rampyari Devi Saraogi v. CIT
67 ITR 84 · 1968 · Supreme Court
616
citing judgments

An assessment order is erroneous and prejudicial to the Revenue's interests if the Assessing Officer accepts a sum offered as income by an assessee, even when that sum was not actually earned, thereby allowing revision under Section 263.

Gee Vee Enterprises v. Addl. CIT
99 ITR 375 · 1975 · High Court
543
citing judgments

An assessment order is erroneous and prejudicial to the interest of revenue if the Assessing Officer fails to make proper inquiries before accepting the assessee's statements or claims. The Commissioner can revise such an order under Section 263 without conducting further inquiries himself.

ITO v. D.G. Housing Projects Ltd.
343 ITR 329 · 2012 · High Court
438
citing judgments

For exercising revisional jurisdiction under Section 263, the Commissioner must first find that the Assessing Officer's order is erroneous and unsustainable in law, as this is a condition precedent. An order is not erroneous merely because two views are possible, or if the Commissioner disagrees with the Assessing Officer's permissible view, or to simply remit the matter for further enquiries.

CIT v. Vikas Polymers
341 ITR 537 · 2012 · High Court
318
citing judgments

An assessment order is not erroneous and prejudicial under Section 263 merely because the Assessing Officer did not record an enquiry and its satisfactory answer in the assessment order, provided such an enquiry was conducted. For revision under Section 263, the Commissioner must also provide the assessee an opportunity of being heard and examine their explanation.

Judgments citing erroneous and prejudicial

R. Yuvaraj, Chennai vs. ITO, Non Corporate Ward-22(5), Chennai

In the result, the appeal filed by the assessee is allowed for statistical purposes

ITA 114/CHNY/2022[2011-12]Status: DisposedITAT Chennai30 Nov 2022AY 2011-12

Bench: Shri V. Durga Rao & Shri G. Manjunathaआयकर अपील सं./I.T.A. No. 114/Chny/2022 िनधा"रण वष"/Assessment Year:2011-12 Shri R. Yuvaraj, Vs. The Income Tax Officer, New No. 1/227, Old No. 1/206, Non Corporate Ward 22(5), Bajanai Koil Street, Medavakkam, Chennai. Chennai 600 100. [Pan:Ahbpy9547N] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri R.S. Balaji, Advocate & Shri B. Sakthivel, Advocate ""थ" की ओर से/Respondent By : Shri D. Hema Bhupal, Jcit सुनवाई की तारीख/ Date Of Hearing : 28.11.2022 घोषणा की तारीख /Date Of Pronouncement : 30.11.2022 आदेश /O R D E R Per V. Durga Rao: This Appeal Filed By The Assessee Is Directed Against The Order Of The Ld. Commissioner Of Income Tax (Appeals) 10, Chennai Dated 05.03.2020 Relevant To The Assessment Year 2011-12. 2. The Appeal Filed By The Assessee Is Delayed By 639 Days In Filing The Appeal Before The Tribunal. The Assessee Has Filed Condonation Petition In The Form Of An Affidavit Explaining The Delay Was Due To 2

For Appellant: Shri R.S. Balaji, Advocate &For Respondent: Shri D. Hema Bhupal, JCIT
Section 142(1)Section 143(2)Section 143(3)Section 263

cause necessary enquiries and examine the facts of the issues raised in the show cause notice dated 21.03.2016 and the omissions are erroneous and prejudicial to the interest of Revenue. Accordingly, the ld. PCIT set aside the assessment order and directed the Assessing Officer for de novo consideration and passing

V.Natarajan, Rasipuram vs. ACIT Central Circle, Salem

The appeals stand allowed in terms of our above order

ITA 468/CHNY/2021[2016-17]Status: DisposedITAT Chennai30 Nov 2022AY 2016-17

Bench: Hon’Ble Shri V. Durga Rao & Hon’Ble Shri Manoj Kumar Aggarwal, Am आयकरअपील सं./ Ita No.467/Chny/2021 (िनधा1रण वष1 / Assessment Year: 2015-16) & आयकरअपील सं./ Ita No.468/Chny/2021 (िनधा1रण वष1 / Assessment Year: 2016-17) Shri V.Natarajan Acit बनाम/ 64C, Rotary Nagar, Central Circle, Vs. Rasipuram -637 408. Salem. "थायीलेखासं./जीआइआरसं./Pan/Gir No. Acgpn-1477-Q (अपीलाथ"/Appellant) : ( !थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Shri T.S. Lakshmi Venkataraman (Ca)-Ld. Ar !थ"कीओरसे/Respondent By : Shri M. Rajan, (Cit)-Ld. Dr सुनवाईकीतारीख/ : 15-11-2022 Date Of Hearing घोषणाकीतारीख / : 30-11-2022 Date Of Pronouncement आदेश / O R D E R Manoj Kumar Aggarwal ():

For Appellant: Shri T.S. Lakshmi Venkataraman (CA)-Ld. ARFor Respondent: Shri M. Rajan, (CIT)-Ld. DR
Section 132Section 143(3)Section 263

making proper inquiry about source of cash deposit of Rs.159.33 Lacs. Finally, invoking Explanation-2 to Sec.263, the order was held to be erroneous and prejudicial to the interest of the revenue and Ld. AO was directed to redo the assessment with a direction to verify genuineness of source ... cases where the Commissioner on examining the records comes to the conclusion that the earlier finding of the Income-tax Officer was erroneous and prejudicial to the interest of the revenue and that fresh determination of the case is warranted. There must be material to justify the Commissioner's finding

V.Natarajan, Rasipuram vs. ACIT Central Circle, Salem

The appeals stand allowed in terms of our above order

ITA 467/CHNY/2021[2015-16]Status: DisposedITAT Chennai30 Nov 2022AY 2015-16

Bench: Hon’Ble Shri V. Durga Rao & Hon’Ble Shri Manoj Kumar Aggarwal, Am आयकरअपील सं./ Ita No.467/Chny/2021 (िनधा1रण वष1 / Assessment Year: 2015-16) & आयकरअपील सं./ Ita No.468/Chny/2021 (िनधा1रण वष1 / Assessment Year: 2016-17) Shri V.Natarajan Acit बनाम/ 64C, Rotary Nagar, Central Circle, Vs. Rasipuram -637 408. Salem. "थायीलेखासं./जीआइआरसं./Pan/Gir No. Acgpn-1477-Q (अपीलाथ"/Appellant) : ( !थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Shri T.S. Lakshmi Venkataraman (Ca)-Ld. Ar !थ"कीओरसे/Respondent By : Shri M. Rajan, (Cit)-Ld. Dr सुनवाईकीतारीख/ : 15-11-2022 Date Of Hearing घोषणाकीतारीख / : 30-11-2022 Date Of Pronouncement आदेश / O R D E R Manoj Kumar Aggarwal ():

For Appellant: Shri T.S. Lakshmi Venkataraman (CA)-Ld. ARFor Respondent: Shri M. Rajan, (CIT)-Ld. DR
Section 132Section 143(3)Section 263

making proper inquiry about source of cash deposit of Rs.159.33 Lacs. Finally, invoking Explanation-2 to Sec.263, the order was held to be erroneous and prejudicial to the interest of the revenue and Ld. AO was directed to redo the assessment with a direction to verify genuineness of source ... cases where the Commissioner on examining the records comes to the conclusion that the earlier finding of the Income-tax Officer was erroneous and prejudicial to the interest of the revenue and that fresh determination of the case is warranted. There must be material to justify the Commissioner's finding

Dhanroop Betala and Sons (HUF), Chennai vs. ITO Non Corporate Ward 4(3), Chennai

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

ITA 1442/CHNY/2019[2014-15]Status: DisposedITAT Chennai30 Nov 2022AY 2014-15

Bench: Shri V. Durga Rao & Shri G. Manjunathaआयकर अपील सं./I.T.A. No. 1442/Chny/2019 िनधा"रण वष"/Assessment Year:2014-15 Dhanroop Betala & Sons (Huf), The Principal Commissioner Of Flat No. L-107, Oswal Garden, Vs. Income Tax – 9, No. 210-212, C.B. Road, Korrukpet, Chennai. Chennai 600 021. [Pan:Aachd0325D] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : None ""थ" की ओर से/Respondent By : Shri M. Rajan, Cit सुनवाई की तारीख/ Date Of Hearing : 21.11.2022 घोषणा की तारीख /Date Of Pronouncement : 30.11.2022 आदेश /O R D E R Per V. Durga Rao: This Appeal Filed By The Assessee Is Directed Against The Order Of The Ld. Principal Commissioner Of Income Tax, Chennai, Dated 21.11.2022 Relevant To The Assessment Year 2014-15 Passed Under Section 263 Of The Income Tax Act, 1961 [“Act” In Short].

For Appellant: NoneFor Respondent: Shri M. Rajan, CIT
Section 143(1)Section 143(3)Section 263

section 263 of the Act, the ld. PCIT has observed that the assessment order passed under section 143(3) of the Act is erroneous and prejudicial to the interest of the Revenue. Accordingly, the ld. PCIT has set aside the assessment order and directed the Assessing Officer to verify

M/S Redisolve Software P Ltd, Chennai vs. DCIT Cor Circle 5 (1), Chennai

In the result, the appeal filed by the assessee in I

ITA 524/CHNY/2018[2012-13]Status: DisposedITAT Chennai30 Nov 2022AY 2012-13

Bench: Shri V. Durga Rao & Shri G. Manjunathaआयकर अपील सं./I.T.A. Nos. 254/Chny/2016 & 521 To 524/Chny/2018 Assessment Years:2010-11, 2009-10, 10-11, 11-12, 12-13 M/S. Redisolve Software P. Ltd., Vs. The Deputy Commissioner Of No. 18, Cenotaph 1St Street, Alwarpet, Income Tax, Chennai 600 035. Corporate Circle 5(1)/5(2), [Pan:Aadcr3467N] Chennai. (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri N. Arjunraj C.A. For Shri S. Sridhar, Advocate ""थ" की ओर से/Respondent By : Shri S. Senthil Kumaran, Cit सुनवाई की तारीख/ Date Of Hearing : 22.11.2022 घोषणा की तारीख /Date Of Pronouncement : 30.11.2022 आदेश /O R D E R Per V. Durga Rao: The Appeal Filed By The Assessee In I.T.A. No. 254/Chny/2016 For The Assessment Year 2010-11 Is Directed Against The Order Of The Ld. Commissioner Of Income Tax –Chennai-5, Chennai Dated 12.03.2015 Passed Under Section 263 Of The Income Tax Act, 1961 [“Act” In Short]. The Appeals Filed By The Assessee In I.T.A. Nos. 521, 522, 523 & 524/Chny/2018 Are Directed Against The Common Order Of The Ld. Commissioner Of Income Tax (Appeals) – 3, Chennai Dated

For Appellant: Shri N. Arjunraj C.A. for Shri S. Sridhar, AdvocateFor Respondent: Shri S. Senthil Kumaran, CIT
Section 10ASection 119(2)(b)Section 139Section 143(3)Section 263

exercising the power conferred under section 263 of the Act, the ld. CIT found that the order passed by the Assessing Officer is erroneous and prejudicial to the interest of the Revenue on the ground that the assessee has not filed its return of income in time under section ... assessee, the Assessing Officer has completed the assessment by allowing the claim of deduction under section 10A of the Act, which is erroneous and prejudicial to the interest of Revenue. Accordingly, the ld. CIT set aside the assessment order passed under section 143(3) of the Act dated

M/S Redisolve Software P Ltd, Chennai vs. DCIT Cor Circle 5 (1), Chennai

In the result, the appeal filed by the assessee in I

ITA 523/CHNY/2018[2011-12]Status: DisposedITAT Chennai30 Nov 2022AY 2011-12

Bench: Shri V. Durga Rao & Shri G. Manjunathaआयकर अपील सं./I.T.A. Nos. 254/Chny/2016 & 521 To 524/Chny/2018 Assessment Years:2010-11, 2009-10, 10-11, 11-12, 12-13 M/S. Redisolve Software P. Ltd., Vs. The Deputy Commissioner Of No. 18, Cenotaph 1St Street, Alwarpet, Income Tax, Chennai 600 035. Corporate Circle 5(1)/5(2), [Pan:Aadcr3467N] Chennai. (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri N. Arjunraj C.A. For Shri S. Sridhar, Advocate ""थ" की ओर से/Respondent By : Shri S. Senthil Kumaran, Cit सुनवाई की तारीख/ Date Of Hearing : 22.11.2022 घोषणा की तारीख /Date Of Pronouncement : 30.11.2022 आदेश /O R D E R Per V. Durga Rao: The Appeal Filed By The Assessee In I.T.A. No. 254/Chny/2016 For The Assessment Year 2010-11 Is Directed Against The Order Of The Ld. Commissioner Of Income Tax –Chennai-5, Chennai Dated 12.03.2015 Passed Under Section 263 Of The Income Tax Act, 1961 [“Act” In Short]. The Appeals Filed By The Assessee In I.T.A. Nos. 521, 522, 523 & 524/Chny/2018 Are Directed Against The Common Order Of The Ld. Commissioner Of Income Tax (Appeals) – 3, Chennai Dated

For Appellant: Shri N. Arjunraj C.A. for Shri S. Sridhar, AdvocateFor Respondent: Shri S. Senthil Kumaran, CIT
Section 10ASection 119(2)(b)Section 139Section 143(3)Section 263

exercising the power conferred under section 263 of the Act, the ld. CIT found that the order passed by the Assessing Officer is erroneous and prejudicial to the interest of the Revenue on the ground that the assessee has not filed its return of income in time under section ... assessee, the Assessing Officer has completed the assessment by allowing the claim of deduction under section 10A of the Act, which is erroneous and prejudicial to the interest of Revenue. Accordingly, the ld. CIT set aside the assessment order passed under section 143(3) of the Act dated

M/S Redisolve Software P Ltd, Chennai vs. DCIT Cor Circle 5 (1), Chennai

In the result, the appeal filed by the assessee in I

ITA 522/CHNY/2018[2010-11]Status: DisposedITAT Chennai30 Nov 2022AY 2010-11

Bench: Shri V. Durga Rao & Shri G. Manjunathaआयकर अपील सं./I.T.A. Nos. 254/Chny/2016 & 521 To 524/Chny/2018 Assessment Years:2010-11, 2009-10, 10-11, 11-12, 12-13 M/S. Redisolve Software P. Ltd., Vs. The Deputy Commissioner Of No. 18, Cenotaph 1St Street, Alwarpet, Income Tax, Chennai 600 035. Corporate Circle 5(1)/5(2), [Pan:Aadcr3467N] Chennai. (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri N. Arjunraj C.A. For Shri S. Sridhar, Advocate ""थ" की ओर से/Respondent By : Shri S. Senthil Kumaran, Cit सुनवाई की तारीख/ Date Of Hearing : 22.11.2022 घोषणा की तारीख /Date Of Pronouncement : 30.11.2022 आदेश /O R D E R Per V. Durga Rao: The Appeal Filed By The Assessee In I.T.A. No. 254/Chny/2016 For The Assessment Year 2010-11 Is Directed Against The Order Of The Ld. Commissioner Of Income Tax –Chennai-5, Chennai Dated 12.03.2015 Passed Under Section 263 Of The Income Tax Act, 1961 [“Act” In Short]. The Appeals Filed By The Assessee In I.T.A. Nos. 521, 522, 523 & 524/Chny/2018 Are Directed Against The Common Order Of The Ld. Commissioner Of Income Tax (Appeals) – 3, Chennai Dated

For Appellant: Shri N. Arjunraj C.A. for Shri S. Sridhar, AdvocateFor Respondent: Shri S. Senthil Kumaran, CIT
Section 10ASection 119(2)(b)Section 139Section 143(3)Section 263

exercising the power conferred under section 263 of the Act, the ld. CIT found that the order passed by the Assessing Officer is erroneous and prejudicial to the interest of the Revenue on the ground that the assessee has not filed its return of income in time under section ... assessee, the Assessing Officer has completed the assessment by allowing the claim of deduction under section 10A of the Act, which is erroneous and prejudicial to the interest of Revenue. Accordingly, the ld. CIT set aside the assessment order passed under section 143(3) of the Act dated

M/S Redisolve Software P Ltd, Chennai vs. DCIT Cor Circle 5 (1), Chennai

In the result, the appeal filed by the assessee in I

ITA 521/CHNY/2018[2009-10]Status: DisposedITAT Chennai30 Nov 2022AY 2009-10

Bench: Shri V. Durga Rao & Shri G. Manjunathaआयकर अपील सं./I.T.A. Nos. 254/Chny/2016 & 521 To 524/Chny/2018 Assessment Years:2010-11, 2009-10, 10-11, 11-12, 12-13 M/S. Redisolve Software P. Ltd., Vs. The Deputy Commissioner Of No. 18, Cenotaph 1St Street, Alwarpet, Income Tax, Chennai 600 035. Corporate Circle 5(1)/5(2), [Pan:Aadcr3467N] Chennai. (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri N. Arjunraj C.A. For Shri S. Sridhar, Advocate ""थ" की ओर से/Respondent By : Shri S. Senthil Kumaran, Cit सुनवाई की तारीख/ Date Of Hearing : 22.11.2022 घोषणा की तारीख /Date Of Pronouncement : 30.11.2022 आदेश /O R D E R Per V. Durga Rao: The Appeal Filed By The Assessee In I.T.A. No. 254/Chny/2016 For The Assessment Year 2010-11 Is Directed Against The Order Of The Ld. Commissioner Of Income Tax –Chennai-5, Chennai Dated 12.03.2015 Passed Under Section 263 Of The Income Tax Act, 1961 [“Act” In Short]. The Appeals Filed By The Assessee In I.T.A. Nos. 521, 522, 523 & 524/Chny/2018 Are Directed Against The Common Order Of The Ld. Commissioner Of Income Tax (Appeals) – 3, Chennai Dated

For Appellant: Shri N. Arjunraj C.A. for Shri S. Sridhar, AdvocateFor Respondent: Shri S. Senthil Kumaran, CIT
Section 10ASection 119(2)(b)Section 139Section 143(3)Section 263

exercising the power conferred under section 263 of the Act, the ld. CIT found that the order passed by the Assessing Officer is erroneous and prejudicial to the interest of the Revenue on the ground that the assessee has not filed its return of income in time under section ... assessee, the Assessing Officer has completed the assessment by allowing the claim of deduction under section 10A of the Act, which is erroneous and prejudicial to the interest of Revenue. Accordingly, the ld. CIT set aside the assessment order passed under section 143(3) of the Act dated

Redisolve Software P Ltd., Chennai vs. DCIT, Chennai

In the result, the appeal filed by the assessee in I

ITA 254/CHNY/2016[2010-11]Status: DisposedITAT Chennai30 Nov 2022AY 2010-11

Bench: Shri V. Durga Rao & Shri G. Manjunathaआयकर अपील सं./I.T.A. Nos. 254/Chny/2016 & 521 To 524/Chny/2018 Assessment Years:2010-11, 2009-10, 10-11, 11-12, 12-13 M/S. Redisolve Software P. Ltd., Vs. The Deputy Commissioner Of No. 18, Cenotaph 1St Street, Alwarpet, Income Tax, Chennai 600 035. Corporate Circle 5(1)/5(2), [Pan:Aadcr3467N] Chennai. (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri N. Arjunraj C.A. For Shri S. Sridhar, Advocate ""थ" की ओर से/Respondent By : Shri S. Senthil Kumaran, Cit सुनवाई की तारीख/ Date Of Hearing : 22.11.2022 घोषणा की तारीख /Date Of Pronouncement : 30.11.2022 आदेश /O R D E R Per V. Durga Rao: The Appeal Filed By The Assessee In I.T.A. No. 254/Chny/2016 For The Assessment Year 2010-11 Is Directed Against The Order Of The Ld. Commissioner Of Income Tax –Chennai-5, Chennai Dated 12.03.2015 Passed Under Section 263 Of The Income Tax Act, 1961 [“Act” In Short]. The Appeals Filed By The Assessee In I.T.A. Nos. 521, 522, 523 & 524/Chny/2018 Are Directed Against The Common Order Of The Ld. Commissioner Of Income Tax (Appeals) – 3, Chennai Dated

For Appellant: Shri N. Arjunraj C.A. for Shri S. Sridhar, AdvocateFor Respondent: Shri S. Senthil Kumaran, CIT
Section 10ASection 119(2)(b)Section 139Section 143(3)Section 263

exercising the power conferred under section 263 of the Act, the ld. CIT found that the order passed by the Assessing Officer is erroneous and prejudicial to the interest of the Revenue on the ground that the assessee has not filed its return of income in time under section ... assessee, the Assessing Officer has completed the assessment by allowing the claim of deduction under section 10A of the Act, which is erroneous and prejudicial to the interest of Revenue. Accordingly, the ld. CIT set aside the assessment order passed under section 143(3) of the Act dated

Invesco Asset Management (India) Private Limited, Mumbai vs. PCIT (Central), Mumbai-3, Mumbai

In the result, the appeal of the assessee is dismissed

ITA 700/MUM/2022[2017-18]Status: DisposedITAT Mumbai30 Nov 2022AY 2017-18

Bench: Shri Aby T. Varkey, Jm & Shri S. Rifaur Rahman, Am आयकर अपील सं/ I.T.A. No.700/Mum/2022 (निर्धारण वर्ा / Assessment Years: 2017-18) Invesco Asset Management बिधम/ Pcit (Central), Mumbai- (India) Pvt. Ltd. 3 Vs. 21St Floor, 2101 “A” Wing, Room No. 612, 6Th Floor Marathon Futurex, Lower Aayakar Bhavan, Parel, Mumbai-400013. Maharshi Karve Road, Mumbai-400020. स्थधयी लेखध सं./जीआइआर सं./Pan/Gir No. : Aaccg3908J (अपीलार्थी /Appellant) .. (प्रत्यर्थी / Respondent) Assessee By: Shri Niraj Seth Revenue By: Shri K. C. Salvamani (Dr) सुनवाई की तारीख / Date Of Hearing: 02/11/2022 घोषणा की तारीख /Date Of Pronouncement: 30/11/2022 आदेश / O R D E R Per Aby T. Varkey, Jm: This Is An Appeal Preferred By The Assessee Against The Action Of The Ld. Principal Commissioner Of Income Tax-3, Mumbai Dated 07.03.2022 For Assessment Year 2017-18 Passed Under Section 263 Of The Income Tax Act, 1961 (Hereinafter Referred To As “The Act”).

For Appellant: Shri Niraj SethFor Respondent: Shri K. C. Salvamani (DR)
Section 143(3)Section 263

Commissioner of Income Tax, Circle 11(1)(1), Mumbai (“the AO”) dated 3.4.2019 on the alleged ground that the said assessment order was erroneous and prejudicial to the interest of the revenue. 2 A.Y. 2017-18 Invesco Asset Management India 2. The learned PCIT erred in invoking the provisions ... there is no reason for setting aside the assessment order on this count and that the order of the Assessing Officer is neither erroneous nor prejudicial to the interest of the Revenue and the action of the Learned PCIT in invoking provisions of section 263 of the Act and directing