“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

Vodafone Idea Ltd., Mumbai vs. Pr CIT -5, Mumbai

ITA 780/MUM/2021[2015-16]Status: DisposedITAT Mumbai28 Jan 2022AY 2015-16

Bench: Shri Kuldip Singh & Shri Amarjit Singhassessment Year: 2015-16

For Appellant: Shri J.D. Mistry, A.RFor Respondent: Shri Dharamveer Singh, D.R

Section 143(3)Section 263Section 32Section 32(1)Section 35A

passed by the Deputy Commissioner of Income Tax - 14(2)(1) (“DCIT”) u/s. 143(3) of the Income- tax Act, 1961 was erroneous and prejudicial to the interests of revenue and in thereby revising the same. 1.2.2. On the facts and circumstances of the case and in law, the Appellant ... submits that the Order passed by the Ld DCIT was neither erroneous nor prejudicial to the interest of the revenue and hence the revision of the same by the PCIT u/s. 263 of the Income-tax Act, 1961 is erroneous and bad in law. 1.2.3. The learned

Shri Pankaj P. Khara, Navi Mumbai vs. Pr. CIT-7, Mumbai

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

ITA 801/MUM/2021[2016-17]Status: DisposedITAT Mumbai27 Jan 2022AY 2016-17

Bench: Shri Prashant Maharishi & Shri Pavan Kumar Gadaleshri Pankaj P Khara, Vs. Pr. Cit-27 64D,Askini, Op Chs Room No. 401, 4Th Ltd,Plotno.20, Secotr- Floor, Tower No. 6, 11, Behind Kanchan Vashi Railway Station Junga, Koparkhairne, Commercial Complex, Navi Mumbai – 400709 Vashi – 400703 "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Akhpk0207E Appellant .. Respondent Appellant By : Ms.Hiral Sejpal.Ca. Dr Respondent By : Mr.Nikhil Chaudhary.Dr Date Of Hearing 06.01.2022 Date Of Pronouncement 31.01.2022 आदेश / O R D E R Per Pavan Kumar Gadale Jm: The Assessee Has Filed The Appeal Against The Order Passed By The Pr.Commissioner Of Income Tax (Pcit)-27, Mumbai Passed U/S 263 Of The Act. The Assessee Has Raised The Following Grounds Of Appeal:

For Appellant: Ms.Hiral Sejpal.CA. DRFor Respondent: Mr.Nikhil Chaudhary.DR

Section 143(2)Section 143(3)Section 263

that the A.O has not verified the details in the course of assessment proceedings and therefore the order passed by the A.O is erroneous and prejudicial to the interest of the revenue. The assessee has filed the reply to the show cause notice on 09.03.2021 mentioning the brief facts ... order cannot be sustained and accordingly set aside the asseseement order passed u/sec143(3) of the Act on 28.12.2018 is erroneous and prejudicial to the interest of the revenue and directed the Assessing officer to pass a fresh assessment order considering the issues dealt in the revision proceedings. Aggrieved

Hotel Owner'S Credit Co-Operative Society, Mysuru vs. Income Tax Officer, Ward-1(1), Mysuru

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

ITA 368/BANG/2021[2015-16]Status: DisposedITAT Bangalore27 Jan 2022AY 2015-16

Bench: Shri George George K, Jm & Shri B.R.Baskaran, Am

For Appellant: Sri.Rampriya Das CAFor Respondent: Sri.Pradeep Kumar, CIT-DR

Section 143(3)Section 263Section 57(2)Section 80Section 80P

views are possible and the AO has taken one view with which the CIT does not agree, it cannot be treated as erroneous and prejudicial to the interests of revenue. The same is view is expressed by the Honorable SC in the case of CIT Vs Green World cooperation

M/S Volvo India Pvt. Ltd., Hosakote vs. CIT, Bangalore

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

ITA 687/BANG/2015[2008-09]Status: DisposedITAT Bangalore27 Jan 2022AY 2008-09

Bench: Shri Chandra Poojari & Smt. Beena Pillaiassessment Year : 2008-09

For Appellant: Shri Pavan Kumar, AdvocateFor Respondent: Shri Pradeep Kumar, Jt.CIT(DR)(ITAT), Bengaluru

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

raising the actual invoice, TDS is effected and therefore, the TDS provisions are not applicable and the assessment cannot be termed as erroneous and prejudicial to the interests of revenue. The ld.CIT(LTU), after considering the explanation of the assessee-company observed that TDS on an amount of Rs.2 ... held that where deduction was allowed by the AO without indicating the basis, that could be considered as an order both erroneous and prejudicial to interests of revenue vide paras.27 & 28 which read as under:- “27. The assessing authority performs a quasi-judicial function and the reasons for his conclusions

Varun Khandelwal, New Delhi vs. Prcit-24, New Delhi

In the result, the appeal of the assessee is allowed

ITA 7891/DEL/2018[2014-15]Status: DisposedITAT Delhi27 Jan 2022AY 2014-15

Bench: Shri Amit Shukla & Dr. B.R.R. Kumar(Through Video Conferencing)

For Appellant: Shri Hiren Mehta, C. AFor Respondent: Shri T. Kipgen, [CIT] – D. R

Section 143(2)Section 143(3)Section 263

satisfied with the material filed by the assessee explaining the source of cash deposit, the assessment order can not be said to be erroneous or prejudicial to the interest of Revenue. c) It was not the case of "no inquiry" and it has been held by various courts that ... been reproduced above) is that, nowhere the ld. Pr. CIT has held that the assessment order passed by the Assessing Officer is erroneous or prejudicial to the interest of Revenue. The basic requisite condition for acquiring the jurisdiction under Section 263 and cancelling the assessment order is that

Wheelabrator Alloy Castings Ltd., Mumbai vs. Pr. CIT - Central- 2, Mumbai

ITA 3410/MUM/2019[2014-15]Status: DisposedITAT Mumbai24 Jan 2022AY 2014-15

Bench: Us, Only Effective Issue To Be Decided In This Appeal Is As To Whether The Ld. Pcit Had Validly Assumed Revisionary Jurisdiction U/S.263 Of The Act In The Facts & Circumstances Of The Instant Case.

Section 142(1)Section 143(3)Section 263Section 79

carried out by the ld. AO with regard to compliance to provisions of Section 79 of the Act, which makes this order erroneous and prejudicial to the interest of the Revenue. Because of this, the ld. PCIT had invoked revision jurisdiction u/s.263 of the Act. We are unable to persuade

Shri Ajaykumar Satrapal Singh, Mumbai vs. CIT -It-4, Mumbai

In the result, this appeal filed by the assessee stand dismissed

ITA 781/MUM/2021[2010-11]Status: DisposedITAT Mumbai21 Jan 2022AY 2010-11

Bench: Shri Shamim Yahya (Am) & Shri Kuldip Singh (Jm)

Section 147Section 148Section 263Section 263(2)Section 50CSection 50C(1)

revision order without appreciating that the original reassessment proceeding was taken place on the very same facts and therefore, the reassessment was neither erroneous nor prejudicial to the interest of revenue within the meaning of section 263 of the Act. (3) On the facts & circumstances it is humbly prayed that ... that failure to make proper enquiries to arrive at the correct and complete facts and to apply the correct law makes assessment order erroneous and prejudicial to the interest of the revenue. In this regard, Ld.CIT 4 referred to several case laws. He also referred to the newly inserted Explanation

M/S I G Petrochemical Limited, Bangalore vs. Deputy Commissioner of Income Tax Circle-3(1)(1), Bangalore

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

ITA 1317/BANG/2018[2006-07]Status: DisposedITAT Bangalore21 Jan 2022AY 2006-07

Bench: Shri N.V. Vasudevan & Shri Chandra Poojariassessment Year: 2006-07

For Appellant: Shri S. Parthasarathi, A.RFor Respondent: Shri Pradeep Kumar, D.R

Section 143(3)Section 2Section 2(24)(vd)Section 263Section 28Section 41(1)

under Section 143(3) of the Act on 20.02.2008. Later on the assessment order was held by Commissioner of Income Tax to be erroneous and prejudicial to the interest of the revenue and accordingly the same was set aside vide order under Section 263 of the Act dated

Sunayana Commercial P. Ltd., Mumbai vs. Pr. CIT -City-3, Mumbai

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

ITA 900/MUM/2021[2011-12]Status: DisposedITAT Mumbai20 Jan 2022AY 2011-12

Bench: Shri Promod Kumar ()And Ms. Suchitra Kamble () Assessment Year: 2011-12 Sunayana Commercial Pvt. Ltd., Pr. Commissioner Of Income Tax, 609, 6Th Floor, Inizio, Cardial Vs. City-3, Room No. 612, 6Th Floor, Gracious Road, Opp. P & G Plaza, Andheri (East), Aayakarbhavan, Maharshikarve Mumbai-400099. Road, Mumbai-400020. Pan No. Aajcs 4896 A Appellant Respondent Assessee By : Mr. Prakash Jhunjhunwala, Ar Revenue By : Mr. Harendra Narayan Singh, Cit-Dr Date Of Hearing : 11/01/2022 Date Of Pronouncement : 20/01/2022

For Appellant: Mr. Prakash Jhunjhunwala, ARFor Respondent: Mr. Harendra Narayan Singh, CIT-DR

Section 142(1)Section 143(1)Section 143(2)Section 143(3)Section 148Section 14ASection 263Section 263d

Assessing Officer does not amount to non-application of mind or non-verification and cannot be treated the assessment order being erroneous and prejudicial to the interest of the Revenue. The Assessing Officer after verifying all the documents more specifically mentioned in the reply filed by the assessee along with ... made by the assessee which amounts to second opinion. This is not permissible u/s 263 as the assessment order does not amount to erroneous and prejudicial to the interest of the Revenue. Hence, the order u/s 263 does not sustain and the appeal of the assessee is allowed

Concern India Foundation, Mumbai vs. Dy CIT (Exem.) - 1(1), Mumbai

In the result, appeal of the assessee is allowed

ITA 1919/MUM/2020[2015-16]Status: DisposedITAT Mumbai19 Jan 2022AY 2015-16

Section 11Section 12ASection 143(3)Section 263

jurisdiction u/s 263 of the Act, the ld . PCIT should bring on record that the order passed by the ld. AO is both erroneous and prejudicial to the interest of the revenue. Reliance in this regard is placed on the decision of Hon’ble Supreme Court in the case ... appears that no inquiry, as such, was undertaken by the PCIT to come to the conclusion that the original assessment order was erroneous and prejudicial to the interests of the Revenue. 10. For the purposes of exercising jurisdiction under Section 263 of the Act, the conclusion that the order

M/S. Asaria Lalji Vador, Mumbai vs. Pr. CIT -7, Mumbai

In the result, appeal filed by the assessee is allowed

ITA 559/MUM/2021[2016-17]Status: DisposedITAT Mumbai12 Jan 2022AY 2016-17

Bench: Shri S. Rifaur Rahman, Hon'Ble & Shri Pavan Kumar Gadale, Hon'Blem/S. Asaria Lalji Vador V. Office Of Pcit – 27 C-21, Mahavir Jyot Room No. 401, 4Th Floor Opp. Odeon Shopping Centre Tower No. 6 Ghatkopar (E), Mumbai -400077 Vashi Railway Station Building Complex Vashi, Navi Mumbai-400703 Pan: Aabpv0149A (Appellant) (Respondent) Assessee By : Shri Pradip Kapasi Department By : Ms. Shailja Rai

For Appellant: Shri Pradip KapasiFor Respondent: Ms. Shailja Rai

Section 143(2)Section 143(3)Section 263Section 54E

adopted the only view permissible in law and the AO has accepted the same, the order of the AO does not become erroneous and prejudicial to the interest of the revenue. i. It is further humbly submitted that the exercise of jurisdiction to revise is contingent upon the Assessment Order ... which the Commissioner does not agree with and which is alleged to result in a loss of revenue, it cannot be treated as erroneous order prejudicial to the interest of revenue, unless the view taken by the Assessing Officer is completely unsustainable in law. The Assessee begs to rely upon

Actia (India) Pvt. Ltd., New Delhi vs. Pr.CIT- 1, New Delhi

In the result, the appeal of the assessee is dismissed

ITA 7552/DEL/2017[2012-13]Status: DisposedITAT Delhi10 Jan 2022AY 2012-13

Bench: Sh. Saktijit Deydr. B. R. R. Kumarita No. 7552/Del/2017 : Asstt. Year : 2012-13 Actia (India) Pvt. Ltd., Vs Pr. Cit-1, 1, Dakshineshwar, 10, Hailey Road, New Delhi New Delhi-110001 (Appellant) (Respondent) Pan No. Aadca6944R Assessee By : None Revenue By : Sh. Mrinal Kumar Das, Sr. Dr Date Of Hearing: 05.01.2022 Date Of Pronouncement: 10.01.2022

For Appellant: NoneFor Respondent: Sh. Mrinal Kumar Das, Sr. DR

Section 142(1)Section 143(2)Section 143(3)Section 234ASection 263Section 92CSection 92C(3)Section 92C(4)

record that there is no lack of enquiry/investigation on the part of the Assessing Officer The order of the Assessing Officer is neither erroneous nor prejudicial to the interest of revenue. Therefore, the provision of section 263 of the Act cannot be invoked. The assessee has no control over ... which was also warranted in the facts of this case and, therefore, the Commissioner was right in holding that such assessment was erroneous and prejudicial to the interest of the Revenue”. In view of the decision of Hon’ble Delhi High Court in the case of M/s Ranbaxy Laboratories

Humuza Consultants, Mumbai vs. The Pr. CIT-19, Mumbai

In the result, appeal filed by the assessee is allowed and the stay application filed by the assessee is dismissed

ITA 726/MUM/2021[2015-16]Status: DisposedITAT Mumbai07 Jan 2022AY 2015-16

Bench: Shri Prashant Maharishi () & Shri Pavan Kumar Gadale () Humuza Consultants Vs The Principal Commissioner Of 6Th Floor, Wokhardt Towers Income-Tax-19, Mumbai Bandra Kurla Complex Room No. 228, 2Nd Floor, Bandra East Matru Mandir Mumbai-400 01 Tardeo Road, Pan : Aahfh9240E Mumbai-400 007 Appellant Respondent Appellant By Shri Jd Mistry & Hiten Chande Respondent By Shri K.K. Mishra (Cit,Dr) Date Of Hearing 07-12-2021 Date Of Pronouncement 07-01-2022 O R D E R Per Prashant Maharishi (Am):

Section 143Section 143(3)Section 263Section 56Section 68

under section 143(3) of the Act on 06/12/2017 by the Assistant Commissioner of Income tax 23(1), Mumbai (The Learned AO) is erroneous and prejudicial to the interest of the revenue. Assessee is aggrieved and therefore in appeal before us. 02. Assessee has raised following grounds of appeal ... taxable u/s 56 (2)(viia) of the act in the hence of the appellant and therefore the assessment order is neither erroneous nor prejudicial to interest of revenue 8) erred in relying on explanation 2 to Section 263 of the act when the same is not applicable Taxability of shares

Kamal Vyas, Mumbai vs. Pr. CIT - 17, Mumbai

In the result, this appeal stand allowed

ITA 303/MUM/2021[2015-16]Status: DisposedITAT Mumbai07 Jan 2022AY 2015-16

Bench: Shri Shamim Yahya (Am) & Shri Amarjit Singh (Jm)

Section 143Section 143(3)Section 263

C.I.T erred in invoking the provisions of section 263 on the ground that the order passed u/s 143(3) was erroneous and prejudicial to the interest of revenue. 3 For that the Ld. Pr. CIT erred in invoking the provisions of sec. 263 when the assessment order passed ... that assessment order passed for A Y 2015-16 in this case u/s. 143(3s) of the Act dated 28.09.2017 appears to be erroneous and prejudicial to the interest of revenue in terms of explanation 2 to section 263 of the Act in view of the following facts

K R Mahesha, Maddur vs. Principal Commissioner of Income Tax, Bangalore-3, Bangalore

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

ITA 365/BANG/2021[2016-17]Status: DisposedITAT Bangalore05 Jan 2022AY 2016-17

Bench: Shri George George K. & Shri B.R. Baskaranassessmentyear:2016-17

For Appellant: Shri S.V. Ravishankar, A.RFor Respondent: Shri Pradeep Kumar, D.R

Section 263Section 271ASection 271BSection 44A

said assessee was maintaining books of account. Accordingly, the Ld PCIT took the view that the assessment order passed by the AO is erroneous and prejudicial to the interests of revenue. Accordingly, he initiated revision proceedings u/s 263 of the Act on both the issues referred above. After affording opportunity ... being heard to the assessee, the Ld. Principal CIT held that the assessment order is erroneous and prejudicial to the interest of the revenue in so far as it is related to allowing deduction of depreciation and interest. He also held that the dropping of penalty proceeding initiated u/s 271A

Ashok Irappa Bannur, Bagalkot vs. Principal Commissioner of Income Tax, Belagavi

In the result appeal filed by assessee stands allowed

ITA 903/BANG/2019[2014-15]Status: DisposedITAT Bangalore29 Dec 2021AY 2014-15

For Respondent: Shri S.V. Ravishankar

Section 143(3)Section 194C(6)Section 263Section 4o

justified in law in invoking the jurisdiction under section 263 of the Act and setting aside the order of the AO, as being "erroneous and prejudicial to Page 2 of 13 the interest of the revenue", which is contrary to fact, on the facts and circumstances of the case ... justified in appreciating that the provision of section 263 of the Act shall be attracted only when the order is both erroneous and prejudicial to the interest of revenue and since the order passed under section 143(3) of the Act was not erroneous, much less prejudicial, the invoking

Vasavi Credit Co-Operative Society Limited, Bangalore vs. Commissioner of Income Tax Officer (TDS), Bangalore

In the result appeal filed by assessee stands allowed

ITA 335/BANG/2021[2016-17]Status: DisposedITAT Bangalore28 Dec 2021AY 2016-17

Bench: Shri. B.R. Baskaran & Smt. Beena Pillaiassessment Year : 2016-17 M/S. Vasavi Credit Co- Operative Society Ltd., No. 108/1, Sri Chakra, The Commissioner Of East Park Road, Income Tax (Tds), Opp. Vasavi Mahal, Bangalore. Malleshwaram, Vs. Bangalore – 560 003. Pan: Aaajv0152C Appellant Respondent Assessee By : Shri S. Ramasubramanyam, Ca Revenue By : Shri Pradeep Kumar, Cit (Dr) Date Of Hearing : 01-12-2021 Date Of Pronouncement : 28-12-2021 Order Per Beena Pillaipresent Appeal Is Filed By Assessee Against Order Dated 29/03/2021 Passed By The Ld.Cit (Tds), Bangalore For Ay 2016- 17 On Following Grounds Of Appeal: “1. That The Order Of The Learned Commissioner Of Income- Tax (Tds) In So Far It Is Prejudicial To The Interests Of The Appellant, Is Bad & Erroneous In Law & Against The Facts & Circumstances Of The Case. 2. That The Learned Commissioner Of Income-Tax (Tds) Erred In Law & On Facts In Invoking Provisions Of Section 263 Of The Act With Respect To The Order Passed U/S. 201(1) & 201(1A) On The Ground That They Are Erroneous & Prejudicial To The Interests Of The Revenue.

For Appellant: Shri S. Ramasubramanyam, CAFor Respondent: Shri Pradeep Kumar, CIT (DR)

Section 18Section 194ASection 194A(3)(i)Section 194A(3)(v)Section 201Section 201(1)Section 263

section 263 of the Act with respect to the order passed u/s. 201(1) and 201(1A) on the ground that they are erroneous and prejudicial to the interests of the Revenue. Page 2 of 6 3. That the learned Commissioner of Income-tax (TDS) erred ... erred in law and on facts in holding that the orders u/s 201(1) and 201(1A) of the Act are erroneous and prejudicial to the interest of the revenue on the grounds that the order is made without any enquiry on violation of provisions of Karnataka Co-operative Societies

ACIT, Central Circle- 17, New Delhi vs. Mera Baba Reality Associate Pvt. Ltd., New Delhi

The appeals of the Revenue are dismissed

ITA 2389/DEL/2018[2011-12]Status: HeardITAT Delhi23 Dec 2021AY 2011-12

Bench: Shri Amit Shukla & Shri Anadee Nath Misshra

For Appellant: Shri S.K. Goyal, CAFor Respondent: Ms. Sarita Kumari, CIT DR

Section 143(3)Section 153ASection 263

vide order dated 28.03.2013 for the AYs 2008-09 to 2011-12 passed u/s 153A/143(3), on the ground that the same are erroneous and prejudicial to the interest of the Revenue. The said assessment order was set aside and was restored to the file of the Assessing Officer

ACIT, Central Circle- 17, New Delhi vs. Mera Baba Reality Associate Pvt. Ltd., New Delhi

The appeals of the Revenue are dismissed

ITA 2388/DEL/2018[2010-11]Status: HeardITAT Delhi23 Dec 2021AY 2010-11

Bench: Shri Amit Shukla & Shri Anadee Nath Misshra

For Appellant: Shri S.K. Goyal, CAFor Respondent: Ms. Sarita Kumari, CIT DR

Section 143(3)Section 153ASection 263

ACIT, Central Circle- 17, New Delhi vs. Mera Baba Reality Associate Pvt. Ltd., New Delhi

The appeals of the Revenue are dismissed

ITA 2386/DEL/2018[2008-09]Status: HeardITAT Delhi23 Dec 2021AY 2008-09

Bench: Shri Amit Shukla & Shri Anadee Nath Misshra

For Appellant: Shri S.K. Goyal, CAFor Respondent: Ms. Sarita Kumari, CIT DR

Section 143(3)Section 153ASection 263