“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

Gora Bai Sahu, Ashok Nagar vs. ITO Ashok Nagar, Ashok Nagar

ITA 35/AGR/2023[2012-13]Status: DisposedITAT Agra15 Sept 2025AY 2012-13

Bench: Shri Sunil Kumar Singh & Shri Brajesh Kumar Singh[Assessment Year: 2012-13] Gora Bai Sahu, Income Tax Officer, Shri Ram Charan Sahu & Ashok Nagar, L/H Late Gora Bai, Sony Vs Madhya Pradesh-473331 Colony, Ashok Nagar, Madhya Pradesh-473331 Pan-Fdzps8877N Appellant Respondent Appellant By Shri Pankaj Gargh, Adv. Respondent By Shri Sukesh Kumar Jain, Cit(Dr) Date Of Hearing 17.07.2025 Date Of Pronouncement 15.09.2025 Order

Section 133(6)Section 143(3)Section 148Section 263

about the genuineness of Source of payment, as is specifically mentioned in the order, it cannot be said that the Assessment Order is erroneous and prejudicial to the interest of revenue. 4. Because in the present case, since the assessment has been0.00 passed u/s 143(3) read with section ... PCIT in this case. Therefore, the assessment order passed u/s 147 of the Act dated 29.11.2019 in this case is erroneous and prejudicial to the interest of the Revenue as the assessment order is passed without making inquiries and verification and allowing relief to the assessee as was required

Zari Silk (India) Private Limited, Jaipur vs. Principal Commissioner of Income Tax (Central), Jaipur

The appeal of the assessee is allowed

ITA 600/JPR/2025[2021-22]Status: DisposedITAT Jaipur15 Sept 2025AY 2021-22

Bench: DR. MITHA LAL MEENA (Accountant Member), DR. S. SEETHALAKSHMI (Judicial Member)

For Appellant: Shri S.R. Sharma, C.A. &For Respondent: Shri Rajesh Ojha, CIT-DR a

Section 115Section 143(3)Section 148BSection 263Section 69A

against the returned income of Rs. 85.16 lacs [rounded off]. The Commissioner, however, was of the opinion that such order of assessment was erroneous and prejudicial to the interest of Revenue. He, therefore, exercised power of revision flowing from Section 263 of the Act. Under such revision order, he held ... verified the required relevant details and as such the assessment order passed in neither M/s Zari Silk (India) Pvt. Ltd. & Arun Palawat, Jaipur. erroneous nor prejudicial to the interest of revenue and the assessee strongly objects the show cause notice issued

Arun Palawat, Jaipur vs. Principal Commissioner of Income Tax, (Central), Jaipur

The appeal of the assessee is allowed

ITA 599/JPR/2025[2021-22]Status: DisposedITAT Jaipur15 Sept 2025AY 2021-22

Bench: DR. MITHA LAL MEENA (Accountant Member), DR. S. SEETHALAKSHMI (Judicial Member)

For Appellant: Shri S.R. Sharma, C.A. &For Respondent: Shri Rajesh Ojha, CIT-DR a

Section 115Section 143(3)Section 148BSection 263Section 69A

Pradeep Kumar Rochwani, Jodhpur vs. Circle (Intl Tax), Jaipur

In the result, appeal of the assessee is allowed

ITA 567/JPR/2025[2018-19]Status: DisposedITAT Jaipur15 Sept 2025AY 2018-19

Bench: DR. MITHA LAL MEENA (Accountant Member), DR. S. SEETHALAKSHMI (Judicial Member)

For Appellant: Shri Rajendra Jain, Adv. (throughFor Respondent: Shri Rajesh Ojha, CIT-DR a

Section 143(3)Section 144C(1)Section 263

facts and in the circumstances of the case, ld. CIT (IT), Delhi-1 grossly erred in holding the order of the AO is erroneous and prejudicial to the interest of the revenue. 5. That on the facts and in the circumstances of the case, ld. CIT (IT), Delhi-1 grossly ... Rajasthan High Court in the case of Commissioner of Income Tax vs. Ganpat Ram Bishnoi, 296 ITR 292 (Raj.). Revision – Erroneous and prejudicial order – Lack of proper enquiry – Tribunal has found that the AO framed the assessment after due application of mind and holding enquiries into all aspects which according

Ashok Nariyani, Jaipur vs. ACIT, Circle-5, Jaipur

In the result, the appeal of the assessee is allowed

ITA 1532/JPR/2024[2017-18]Status: DisposedITAT Jaipur15 Sept 2025AY 2017-18

For Appellant: Sh.Deepak Sharma, Adv. &For Respondent: Mrs. Anita Rinesh, JCIT, Sr.-DR

Section 115BSection 131Section 142(1)Section 143(1)Section 143(2)Section 143(3)Section 68

liable to be paid @ 60% under section 115BBE of the Act which the Ld. AO failed to do. Therefore, his order was erroneous and prejudicial to the interest of Revenue which he set aside with direction to the Ld. AO to pass fresh order in accordance with law. 7. Aggrieved ... taxed as per provisions of section 115BBE of the Act and having not done so, whether the order of the Assessing Officer is erroneous and prejudicial to the interest of the Revenue. 14. At the very outset, we would like to state that an amendment has been brought in section

Muthyala Suryababu, Bengaluru vs. Pr. Commissioner of Income Tax, Bangalore-1, Bangalore

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

ITA 854/BANG/2025[2020-21]Status: DisposedITAT Bangalore15 Sept 2025AY 2020-21

Bench: Shri Waseem Ahmed & Shri Keshav Dubeyassessment Year : 2020-21

For Appellant: Shri H. Guruswamy, ITPFor Respondent: Shri Murali Mohan, CIT DR

Section 14Section 263Section 55

Page 2 of 8 3. The Ld. PCIT Bangalore - 1 has erred in holding that the Assessment Order dated 28-08-2022 was erroneous and prejudicial to the interest of Revenue without appreciating the facts and circumstances of the case. 4. The Ld. PCIT Bangalore - 1 has erred in holding ... Considering the fact of the case, the ld. PCIT held that assessment order passed u/s. 143(3) of the Act dated 28.08.2022 is erroneous and prejudicial to the interest of revenue in so far as the AO had passed the order without examining the fact that whether impugned expenditure

Sha Pratapchand Pukharaj and Company, Vijayapur vs. Income Tax Officer, Ward-1 & Tps, Bijapur

In the result, the appeal of the assessee is allowed

ITA 2547/BANG/2024[2017-18]Status: DisposedITAT Bangalore15 Sept 2025AY 2017-18

Bench: Shri Waseem Ahmed & Shri Keshav Dubeyassessment Year : 2017-18

For Appellant: Smt. Pratibha R., A.RFor Respondent: Sri Subramanian S., D.R

Section 253Section 253(5)Section 263

accepted the explanation of the assessee without making any enquiry and thus the order passed by the AO is erroneous and prejudicial to the interest of revenue and hence show cause notice was issued on 14.03.2022 giving the assessee an opportunity to explain why the assessment order be not revised ... cash deposits should have been added to the income of theassessee. Considering these facts, the ld. PCIT held that the assessment order is erroneous and prejudicial to the interest of revenue interms of section 263 of the Act and accordingly set-aside the assessment order and directed

Vanigota Sugar Trading Company, Vijapur vs. Income Tax Officer, Ward-1 & Tps, Bijapur

In the result, the appeal of the assessee is allowed

ITA 2545/BANG/2024[2017-18]Status: DisposedITAT Bangalore15 Sept 2025AY 2017-18

Bench: Shri Waseem Ahmed & Shri Keshav Dubeyassessment Year : 2017-18

For Appellant: Smt. Pratibha R., A.RFor Respondent: Sri Subramanian S., D.R

Section 253(5)Section 263

books, specially by obtaining the cash book. As the AO had not conducted necessary enquiries and thus order passed by the AO is erroneous and prejudicial to the interest of revenue and accordingly the show cause notice was issued on 14.03.2022 giving the assessee an opportunity to explain ... unexplained cash deposits should have been added to the assessee income. Considering these facts, the ld. PCIT held that the assessment order is erroneous and prejudicial to the interest of revenue in terms of section 263 of the Act and accordingly, set-aside the assessment order and directed

Chandan Steel Limited, Mumbai vs. Principal Commissioner of Income Tax Officer, Mumbai 4, Mumbai

ITA 3444/MUM/2025[2020-21]Status: DisposedITAT Mumbai15 Sept 2025AY 2020-21

Bench: Shri Vikram Singh Yadav & Shri Rahul Chaudhary

For Appellant: Shri Rakesh JoshiFor Respondent: Shri R.A. Dhyani, CIT-DR

Section 143(3)Section 263Section 37(1)Section 80G

Principal CIT has erred in considering the order passed u/s.143(3) of the Income Tax Act, 1961 by the Learned Assessing officer as erroneous and prejudicial to the interest of the revenue, without appreciating the facts and circumstances of the case. 4. On the fact and circumstances of the case ... expenditure u/s.80G of the Act, which is not allowable and it was accordingly held that the assessment order passed by the AO was erroneous and prejudicial to the interest of the Revenue within the meaning of section 263 of the Act. In response to the show cause, the assessee filed

M/S. Chennai Business Tower Pvt. Ltd., Kanchipuram vs. PCIT-4, Chennai

In the result, the appeal of the assessee is allowed

ITA 1570/CHNY/2025[2010-11]Status: DisposedITAT Chennai12 Sept 2025AY 2010-11

Bench: Shri Aby T Varkey & Shri S. R. Raghunathaआयकर अपील सं./Ita Nos.: 1570/Chny/2025, धनिाारण वर्ा / Assessment Years: 2010-11 M/S. Chennai Business Tower Pcit-4, Private Limited (Formerly Known Vs Chennai. As Rmz Infinity (Chennai) Pvt. . Ltd), 110, Mount Poonamallee Road, Porur, Porur S.O. Kanchipuram – 600 116. [Pan:Aaacd-2287-R] (अपीलाथी/Appellant) (प्रत्यथी/Respondent) अपीलाथी की ओर से/Appellant By : Shri. B. Ramakrishnan, Fca. प्रत्यथी की ओर से/Respondent By : Shri. R. Raghupathy, Addl. Cit. सुनवाई की तारीख/Date Of Hearing : 06.08.2025 घोर्णा की तारीख/Date Of Pronouncement : 12.09.2025 आदेश /O R D E R Per S. R. Raghunatha, Am:

For Appellant: Shri. B. Ramakrishnan, FCAFor Respondent: Shri. R. Raghupathy, Addl. CIT

Section 143(1)Section 154Section 24Section 263

u/s.24 of Rs.1,09,28,075/-. Thus the rectification order dated 19.07.2022 (correct date of order u/s.154 was 02.06.2022) was found to be erroneous and prejudicial to the interests of the revenue and hence after issuing the statutory notices and on perusal of the replies of the assessee passed ... ld.AR for the assessee Mr.B.Ramakrishnan, FCA, assailing the action of the ld.PCIT, submitted that the order u/s.154 of the Act neither erroneous nor prejudicial to the interest of the revenue. The ld.AR drew our attention to the issue of treatment of rental income of the assessee under the head ‘income

Savex Technologies Private Limited, Mumbai vs. Principal Commissioner of Income Tax, Mumbai

The appeal stands allowed

ITA 4185/MUM/2025[2020-21]Status: DisposedITAT Mumbai12 Sept 2025AY 2020-21

Bench: Justice (Retd.) C.V. Bhadang & Ms. Padmavathy S.: A.Y. : 2020-21

For Appellant: Shri Vishal Shah, CAFor Respondent: Shri Arun Kanti Datta, CIT-DR

Section 135Section 143(1)Section 143(3)Section 263Section 37Section 37(1)Section 80G

learned PCIT has elaborately considered the matter, including the applicable decisions, and has rightly come to the conclusion that the assessment order is erroneous and prejudicial to the interest of Revenue. It is submitted that various decisions to the contrary passed by the Tribunal are subject matter of challenge before

Augmont Enterprises Private Limited, Mumbai vs. ACIT - Circle 6(1)(2), Mumbai

In the result, appeal filed by the assessee is allowed in above terms

ITA 3096/MUM/2025[2020-21]Status: DisposedITAT Mumbai12 Sept 2025AY 2020-21

Bench: Shriom Prakash Kant & Shri Raj Kumar Chauhanaugmont Enterprises Pvt. Ltd. Acit Circle-6(1)(2), 201, A/B & 202, 2Nd Floor, Trade Vs. R. No. 506, 5Th Floor, Aayakar World, D-Wing, Kamala Mills Bhavan, Mumbai-400 020 Compound, S. B. Marg, Lower Parel (West), Mumbai-400 003. Pan: Aagcr3007D (Appellant) (Respondent) Assessee Represented By : Ms. Ridhisha Jain, Ld. Ar Department Represented By : Shri Rajesh Kumar Yadav, Ld. Dr Date Of Conclusion Of Hearing : 05.08.2025 Date Of Pronouncement : 12.09.2025

Section 143(2)Section 143(3)Section 263Section 37(1)Section 41Section 80G

Enterprises Pvt. Ltd. 2020-21 wherein the assessment order u/s 143(3) r.w.s. 144B of the Act dated 26.09.2022 was set aside being erroneous and prejudicial to the interest of revenue. 2. The brief facts of the case are that, the assessee company is engaged in the business of trading ... assessee were brought to the notice of the AO who accepted the same and as such the order of the AO is neither erroneous nor prejudicial to the interest of revenue and it is only a change of opinion and for this reasons, the notice has been issued. Even

Chemical Process Piping Pvt Ltd, Mumbai vs. Principal Commissioner of Income Tax -6, Mumbai

In the result, the appeal filed by the assessee is allowed in above terms

ITA 2953/MUM/2025[2020-21]Status: DisposedITAT Mumbai12 Sept 2025AY 2020-21

Bench: Shriom Prakash Kant & Shri Raj Kumar Chauhanm/S. Chemical Process Piping Pcit, Mumbai-6, Pvt. Ltd. Vs. R. No. 501, Aayakar Bhavan, Ground Floor, Cpe Plot, B.S.D. Marg, Churchgate, Mumbai-400 Govandi, Mumbai-400 088 020 Pan: Aaccc6212D (Appellant) (Respondent) Assessee Represented By : Shri Nishit Gandhi & Shri Harshad Shah, Ld. Ars Department Represented By : Shri R. A. Dhyani, Ld. Dr Date Of Conclusion Of Hearing : 12.06.2025 Date Of Pronouncement : 12.09.2025

Section 143(3)Section 263Section 37(1)Section 80G

Piping Pvt. Ltd. 2020-21 wherein the assessment order u/s 143(3) r.w.s. 144B of the Act dated 12.09.2022 was set aside being erroneous and prejudicial to the interest of revenue by the Ld. CIT(A). 2. The brief facts of the case are that, the assessee company is engaged ... assessee were brought to the notice of the AO who accepted the same and as such the order of the AO is neither erroneous nor prejudicial to the interest of revenue and it is only a change of opinion and for this reasons, the notice has been issued. Even

Ambience Developers and Infrastructure Private Limited, Delhi vs. PCIT (Central) Delhi-2, Jhandewalan New Delhi, Delhi

ITA 1869/DEL/2025[2020-21]Status: DisposedITAT Delhi12 Sept 2025AY 2020-21

Bench: Ms. Madhumita Roy & Shri Naveen Chandra

For Appellant: Sh. Mahesh Kumar CA &For Respondent: Sh. Mahesh Kumar, CIT, DR

Section 142(1)Section 143(1)Section 143(2)Section 143(3)Section 263

dated 03.08.2021 under Section 143(3) of the Act accepting the returned loss of Rs.19,52,51,093/- for Assessment Year 2018-19 erroneous and prejudicial to the interest of revenue on account of incorrect categorization of business income as rental income, incorrect claim of interest expense against business income ... could not have imposed or substituted his opinion on the view taken by the A.O., to say that the subject assessment order was erroneous and prejudicial to the interest of the revenue (relevant excerpt reproduced below): "24. We are supported y the view of the Apex Court in the case

Ambience Developers and Infrastructure Private Limited, Delhi vs. PCIT (Central), Delhi-2 Jhandewalan, New Delhi, Delhi

ITA 1868/DEL/2025[2018-19]Status: DisposedITAT Delhi12 Sept 2025AY 2018-19

Bench: Ms. Madhumita Roy & Shri Naveen Chandra

For Appellant: Sh. Mahesh Kumar CA &For Respondent: Sh. Mahesh Kumar, CIT, DR

Section 142(1)Section 143(1)Section 143(2)Section 143(3)Section 263

Rahul Rastogi, New Delhi vs. PCIT, Ghaziabad

ITA 844/DEL/2024[2013-14]Status: DisposedITAT Delhi12 Sept 2025AY 2013-14

Bench: Shri S Rifaur Rahman & Shri Anubhav Sharma

Section 147Section 151Section 263

IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH, ‘A’: NEW DELHI BEFORE SHRI S RIFAUR RAHMAN, ACCOUNTANT MEMBER AND SHRI

Muniyappa Muniraju, Bengaluru vs. Pr. Commissioner of Income Tax, Bengaluru-2, Bengaluru

In the result, appeal filed by the assessee is allowed

ITA 1119/BANG/2025[2017-18]Status: DisposedITAT Bangalore11 Sept 2025AY 2017-18

Bench: Shri Laxmi Prasad Sahu & Shri Soundararajan Kassessment Year : 2017-18 Shri. Muniyappa Muniraju, Vs. Pr. Cit, No.1/3, 1St Cross, Muni Narasimhaiah Bangalore - 2. Garden, Chocolate Factory Main Road, Btm I Stage, Bangalore – 560 029, Karnataka. Pan : Anjpm 0458 N Appellant Respondent Assessee By : Shri. Narendra Sharma, Advocate Revenue By : Shri. Muthu Shankar, Cit(Dr)(Itat), Bangalore. Date Of Hearing : 04.09.2025 Date Of Pronouncement : 11.09.2025

For Appellant: Shri. Narendra Sharma, AdvocateFor Respondent: Shri. Muthu Shankar, CIT(DR)(ITAT), Bangalore

Section 139(1)Section 142(1)Section 143(2)Section 147Section 148Section 194CSection 194HSection 263Section 44A

information available he accepted the return of income. Accordingly, as per provisions of income tax Act, Order passed by the AO is erroneous and prejudicial to the interest of Rvenue. During the proceedings before the learned Pr.CIT, assessee explained that the Page 3 of 9 gross turnover for the year ... revision under section 263 of the Act, dated 12/03/2024, held that the order of re- assessment passed by the learned assessing officer is erroneous and prejudicial to the interest of the revenue and set-aside the order of reassessment passed directed the learned assessing to make fresh assessment.  The learned

Fusion Granito Private Limited, Morbi vs. The Pr. Commissioner of Income Tax - 1, Rajkot

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

ITA 190/RJT/2023[2018-19]Status: DisposedITAT Rajkot10 Sept 2025AY 2018-19

Bench: Dr. A. L. Saini, Am & Shri Dinesh Mohan Sinha, Jm आयकर अपील सं./Ita No.190/Rjt/2023 (िनधा"रण वष" / Assessment Year: (2018-19) (Physical Hearing) Fusion Granito Pvt. Ltd. बनाम/ Principal Commissioner Of Income Revenue Survey No.555/P1/91, Tax-1, Vs. Nr. Khokhra Hanuman Temple, 2Nd Jetpar Road, Morbi-363641 Rajkot, Floor, “Aayakar Bhawan”, Race Course Ring Road, Rajkot-360001 "ायीलेखासं./जीआइआरसं./Pan/Gir No.: Aadcf 0696 B (अपीलाथ"/Appellant) (""थ" /Respondent) अपीलाथ" ओर से/ Appellant By Shri Bandish Soparkar, Ar ""थ" की ओर से/Respondent By Shri Praveen Verma, Cit Dr सुनवाई की तारीख/Date Of Hearing 24/06/2025 घोषणा की तारीख /Date Of Pronouncement 10/09/2025 आदेश / O R D E R Per Dr. Arjun Lal Saini, A.M By Way Of This Appeal, The Assessee Has Challenged The Correctness Of The Order Passed By The Learned Principal Commissioner Of Income Tax - 1, Rajkot [In Short ‘Ld. Pcit’], Dated 27.03.2023, Under Section 263 Of The Income Tax Act, 1961 [Hereinafter Referred To As The ‘Act’] For The Assessment Year (Ay) 2018-19. 2. Grievances Raised By The Assessee, Which, Being Interconnected, Will Be Taken Up Together, Are As Follows: “1. The Revision Order U/S 263 Of The Act Dated 28.03.2023 Is Bad In Law. 2. The Hon’Ble Pr. Cit-1, Rajkot Has Erred In Law As Well As On Facts In Completing The Revision Proceedings U/S 263 Of The Act Hurriedly In Short Span Of Time Fusion Granito Pvt. Ltd.

Section 143(3)Section 263Section 68

facts in not considering the submissions of the appellant in true perspective on the strength of which the assessment order was neither erroneous nor prejudicial to the interest of revenue and therefore, the provisions of Section 263 of the Act were not applicable to the case of the appellant ... assessment proceedings asssessee submitted reply party-wise, and assessing officer examined the issue. Therefore, order passed by the assessing officer is neither erroneous nor prejudicial to the interest of the revenue. However, the Ld.PCIT rejected the contention of assessee and held that assessing officer has not examined the source

Sachin Notified Area, Surat vs. Pr. CIT, Surat

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

ITA 248/SRT/2024[2015-16]Status: DisposedITAT Surat10 Sept 2025AY 2015-16

Bench: Shri Dinesh Mohan Sinha & Shri Bijayananda Pruseth

Section 10(20)Section 143(1)Section 144Section 147Section 263

grievously erred in setting aside the assessment order u/s.147 rws.144B of the Act without pointing out as to how the order is erroneous and prejudicial to interest of revenue. 9. It is therefore prayed that the above proposed proceedings may please be revoked as learned members of the tribunal

Sachin Notified Area, Surat vs. Pr. CIT, Surat

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

ITA 247/SRT/2024[2014-15]Status: DisposedITAT Surat10 Sept 2025AY 2014-15

Bench: Shri Dinesh Mohan Sinha & Shri Bijayananda Pruseth

Section 10(20)Section 143(1)Section 144Section 147Section 263