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“prejudicial to interest of revenue”

Rectification & RevisionSection 263Section 263273 judgments

JIGNASA ATULKUMAR SHAH,AHMEDABAD vs. THE PR.CIT-1, AHMEDABAD

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

ITA 1140/AHD/2025[2018-19]Status: DisposedITAT Ahmedabad24 Feb 2026AY 2018-19

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

Section 10(38)Section 147Section 148Section 69Section 69A

consideration as unaccounted income. 7. The Ld. PCIT has erred in law and on facts in considering assessment order as erroneous and prejudicial to interest of revenue. 8. The appellant craves liberty to add, amend, alter or modify all or any grounds of appeal before final appeal. 5. Heard rival

SMALL INDUSTRIES DEVELOPMENT BANK OF INDIA,MUMBAI vs. CIRCLE 3(3)(1), MUMBAI, MUMBAI

In the result, appeal of the assessee is partly allowed

ITA 2763/MUM/2025[2020-21]Status: DisposedITAT Mumbai17 Feb 2026AY 2020-21

Bench: Smt. Beena Pillai & Shri Girish Agrawalassessment Year: 2020-21

For Appellant: Shri Rakesh Joshi, CAFor Respondent: Shri Arun Kanti Datta, CIT DR
Section 143(3)Section 263

Income Tax Act, 1961 (the Act) without bring out as to how the assessment order was erroneous and prejudicial to interest of revenue. 2 Small Industries Development Bank of India AY 2020-21 2. On the fact and circumstances of the case as well as in Law, the Learned Principal

KAMUTHI SOLAR POWER LIMITED (MERGED WITH ADANI GREEN ENERGY TWENTY -THREE LTD.),AHMEDABAD vs. THE PR. CIT, AHMEDABAD-1, AHMEDABAD

In the result, appeal of the assessee is allowed

ITA 1242/AHD/2025[2020-21]Status: DisposedITAT Ahmedabad13 Feb 2026AY 2020-21

Bench: Dr. B.R.R. Kumar, Vice-Shri Siddhartha Nautiyalkamuthi Solar Power Limited Vs. Principal Commissioner Of (Merged With Adani Green Income-Tax, Energy Twenty Three Ltd.), Ahmedabad-1 Adani House, Nr. Mithakhali Six Roads, Ahmedabad-380009 [Pan :Aafck 8399 E] (Appellant) .. (Respondent) Appellant By : Shri Biren Shah, Ar Respondent By: Shri R.P. Rastogi, Cit-Dr Date Of Hearing 10.12.2025 Date Of Pronouncement 13.02.2026

For Appellant: Shri Biren Shah, ARFor Respondent: Shri R.P. Rastogi, CIT-DR
Section 115BSection 143(3)Section 144BSection 263

Assessing Officer and he duly applied his mind and not made addition. Thus, the assessment order was not erroneous and prejudicial to interest of revenue. 4. In law and in the facts and the circumstances of the case of the appellant, the Ld. PCIT has erred in concluding that ... Assessing Officer and he duly applied his mind and not made addition. Thus, the assessment order was not erroneous and prejudicial to interest of revenue. 5. In law and in the facts and the circumstances of the case of the appellant, the Ld. PCIT has grossly erred in ignoring

HOLLIS VITRIFIED PRIVATE LIMITED,MORBI, GUJARAT, INDIA vs. THE PRINCIPAL COMMISSIONER OF INCOME TAX - 1, RAJKOT, RAJKOT, GUJARAT, INDIA

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

ITA 363/RJT/2024[2018-19]Status: DisposedITAT Rajkot12 Feb 2026AY 2018-19

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinhaआयकरअपीलसं./Ita No. 363/Rjt/2024 (Assessment Year: 2018-19) (Hybrid Hearing) Hollis Vitrified Pvt. Ltd. Vs. The Pr. Commissioner Of Income Revenue Survey No. 756/P1/P1/P1, Opp. Tax-1, Rajkot Antique Granito, Ghuntu,-Lakhdhirpur Road, Morbi (Gujarat)-363642 "ायीलेखासं./जीआइआरसं./Pan/Gir No.: Aacch5628Q (अपीलाथ"/Appellant) (""थ"/Respondent)

For Appellant: Shri Fenil H. Mehta, Ld. ARFor Respondent: Shri Sanjay Punglia, CIT-DR
Section 143(3)Section 263Section 68

said share capital investment, enquiry made by Assessing Officer was not adequate and accordingly, order passed by Assessing Officer was erroneous and prejudicial to interests of revenue. (4)In the case of Umesh Krishnani v. ITO [2013] 35 taxmann.com 598/217 Taxman 13 (Gujarat), the Gujarat High Court held that where ... result of which substantial amount of taxable income was not brought to tax, Commissioner rightly held assessment order as erroneous and prejudicial to interest of revenue. In view of the above facts, it was observed by ld. PCIT that the order passed u/s 143(3) r.w.s

STUDDS ACCESSORIES LIMITED,FARIDABAD vs. THE PRINCIPAL COMMISSIONER OF INCOME TAX, FARIDABAD, FARIDABAD

In the result, appeal filed by the assessee is allowed

ITA 3570/DEL/2025[2020-21]Status: DisposedITAT Delhi12 Feb 2026AY 2020-21

Bench: Shri S. Rifaur Rahman & Shri Raj Kumar Chauhan

For Appellant: Sh. Vishal Kalkra, Adv &For Respondent: Sh. Avikal Manu, CIT DR
Section 14Section 143(3)Section 144BSection 263Section 80J

Bang. - Trib.) - Narayan Tatu Rane vs ITO: [2016] 70 taxmann.com 227/ITA No. 2690,2691 of 2016 (Mum. Trib.) Assessment Order not prejudicial to interest of revenue: g) Reliance is placed on following decisions wherein it has been held that that even if the assessing officer adopts one of the courses

JAIN ENTERPRISES, BHILAI,DURG vs. PCIT, RAIPUR-1, RAIPUR

In the result, appeal of the assessee is dismissed as above

ITA 187/RPR/2025[2018-19]Status: DisposedITAT Raipur11 Feb 2026AY 2018-19

Bench: Shri Partha Sarathi Chaudhury, Jm & Shri Avdhesh Kumar Mishra, Am आयकर अपील सं. / Ita No: 187/Rpr/2025 (िनधा"रण वष" Assessment Year: 2018-19) Jain Enterprises, Vs Pr. Commissioner Of Income Tax, 87-B, Light Industrial Area, Raipur-1, Central Revenue Building, Bhilai-490026, C.G. Civil Lines, Raipur, 492001, C.G. Pan: Aagfj3469G (अपीलाथ"/Appellant) (""थ" / Respondent) : िनधा"रती की ओर से / Assessee By : Shri S. R. Rao, Advocate राज" की ओर से / Revenue By : Shri Ram Tiwari, Cit-Dr सुनवाई की तारीख / Date Of Hearing : 07/01/2026 घोषणा की तारीख / Date Of : 11/02/2026 Pronouncement आदेश / O R D E R Per Avdhesh Kumar Mishra, Am: This Appeal For Assessment Year (‘Ay’) 2018-19 Filed By The Assessee Is Directed Against The Order Dated 24.03.2025 Of The Principal Commissioner Of Income Tax, Raipur-1 (‘Pcit’) Passed Under Section 263 Of The Income Tax Act, 1961 (‘Act’).

For Appellant: Shri S. R. Rao, AdvocateFor Respondent: Shri Ram Tiwari, CIT-DR
Section 142(1)Section 147Section 148Section 263

verification which should have been made, the same shall be deemed to be erroneous and in so far as it is prejudicial to interest of revenue. Applying the law laid down by the Hon’ble Supreme Court in the case of Paville Project Pvt. Ltd. (supra) to the facts

AMBUJA CEMENTS LIMITED,MUMBAI vs. PCIT, MUMBAI-3, MUMBAI

In the result, the appeal filed by the assessee is\ndismissed

ITA 3474/MUM/2025[2019-20]Status: DisposedITAT Mumbai05 Feb 2026AY 2019-20
For Appellant: \nShri Sourabh Soparkar, AR (virtually appear)For Respondent: \nShri Rajesh Kumar Yadav, (CIT-DR)
Section 143(3)Section 14ASection 263

stating that the assessment order is erroneous\nwithout making any independent inquiry to satisfy himself that\nassessment order is erroneous and prejudicial to interest of revenue.\n4.3 In law and in the facts and the circumstances of the case of the appellant,\nthe Ld. PCIT has erred in stating that

CONE CRAFT PAPER PVT LTD,DELHI vs. PCIT-1, DELHI

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

ITA 3592/DEL/2025[2021-22]Status: DisposedITAT Delhi29 Jan 2026AY 2021-22

Bench: Shri S. Rifaur Rahman & Shri Raj Kumar Chauhan

Section 133(6)Section 142(1)Section 143(2)Section 263

that it is only lack of inquiry and not inadequacy of inquiry which may make the assessment order as erroneous and thus, prejudicial to interest of Revenue so that Jurisdictional u/s 263 of the Act can be exercised by the Ld. PCIT. The Hon'ble High Court of Delhi recently

SHREE VEGAM URBAN CO OP CREDIT SOCIETY LIMITED ,SURAT vs. ACIT, CIRCLE-1(2), SURAT

In the result, the appeal of the assessee is allowed

ITA 252/SRT/2025[2017-18]Status: HeardITAT Surat22 Jan 2026AY 2017-18

Bench: Dr. B.R.R. Kumar, Vice-Ms Suchitra Raghunath Kamble

For Appellant: Shri Shaunak K. Zaveri, CAFor Respondent: Ms Namita Patel, Sr. DR
Section 194ASection 194A(3)(v)Section 250Section 263Section 80PSection 80P(2)(d)Section 80P(4)

earned by assessee, a cooperative society, from investment made with a cooperative bank under section 80P(2)(d) which was erroneous and prejudicial to Interest of revenue Tribunal reversed Principal Commissioner's order holding that cooperative bank was a cooperative society registered under Gujarat State Cooperative Societies Act and, therefore

CHARAT SINGH,SIRSA vs. PCIT ROHTAK, ROHTAK

The appeal is dismissed

ITA 2087/DEL/2024[2018-19]Status: DisposedITAT Delhi21 Jan 2026AY 2018-19

Bench: Shri Anubhav Sharma & Shri Manish Agarwalsh. Charat Singh Vs. Principal Commissioner Of 1 Dhani Amar Singhwali, Income Tax, Aaykar Village Khairpur Sirsa Bhavan, Opp. Mansarover 125055, Haryana, India Park, Rohtak, Haryana – 124001 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Dtbps4489C Appellant .. Respondent

For Appellant: Sh. Ankit Kumar, AdvFor Respondent: Ms. PoojaSwaroop, CIT, DR
Section 143(3)Section 145ASection 263Section 28Section 56(2)(viii)

Punjab Haryana High Court the assessment concluded by assessing officer of jurisdiction of Haryana, leads to assessment order being prejudicial to interest of revenue. Relevant para 36 is reproduced; “36. There is no doubt to the legal proposition, as cited by Ld Counsel of appellant, that the assessment order need

VIIKING MEDIA AND ENTERTAINMENT PVT. LTD.,MUMBAI vs. DCIT- CENTRAL CIRCLE 2(2), MUMBAI CITY

In the result, all the appeals of the assessee are dismissed

ITA 3433/MUM/2025[2021-22]Status: DisposedITAT Mumbai20 Jan 2026AY 2021-22

Bench: Shri Sandeep Gosain () & Shri Om Prakash Kant ()

For Appellant: Mr. Rajjev KhandelwalFor Respondent: 18/11/2025
Section 132(1)Section 143(3)Section 153ASection 263

interest of could not be held to be erroneous and prejudicial to interest of could not be held to be erroneous and prejudicial to interest of revenue when Assessing Officer could n revenue when Assessing Officer could not have travelled beyond ot have travelled beyond issues forming subject matter

VIIKING MEDIA AND ENTERTAINMENT PVT. LTD.,MUMBAI vs. DCIT- CENTRAL CIRCLE 2(2), MUMBAI CITY

In the result, all the appeals of the assessee are dismissed

ITA 3432/MUM/2025[2020-21]Status: DisposedITAT Mumbai20 Jan 2026AY 2020-21

Bench: Shri Sandeep Gosain () & Shri Om Prakash Kant ()

For Appellant: Mr. Rajjev KhandelwalFor Respondent: 18/11/2025
Section 132(1)Section 143(3)Section 153ASection 263

interest of could not be held to be erroneous and prejudicial to interest of could not be held to be erroneous and prejudicial to interest of revenue when Assessing Officer could n revenue when Assessing Officer could not have travelled beyond ot have travelled beyond issues forming subject matter

VIIKING MEDIA AND ENTERTAINMENT PVT. LTD.,MUMBAI vs. DCIT- CENTRAL CIRCLE 2(2), MUMBAI

In the result, all the appeals of the assessee are dismissed

ITA 3431/MUM/2025[2019-20]Status: DisposedITAT Mumbai20 Jan 2026AY 2019-20

Bench: Shri Sandeep Gosain () & Shri Om Prakash Kant ()

For Appellant: Mr. Rajjev KhandelwalFor Respondent: 18/11/2025
Section 132(1)Section 143(3)Section 153ASection 263

interest of could not be held to be erroneous and prejudicial to interest of could not be held to be erroneous and prejudicial to interest of revenue when Assessing Officer could n revenue when Assessing Officer could not have travelled beyond ot have travelled beyond issues forming subject matter

VIIKING MEDIA AND ENTERTAINMENT PVT. LTD.,MUMBAI vs. DCIT- CENTRAL CIRCLE 2(2), MUMBAI

In the result, all the appeals of the assessee are dismissed

ITA 3430/MUM/2025[2018-19]Status: DisposedITAT Mumbai20 Jan 2026AY 2018-19

Bench: Shri Sandeep Gosain () & Shri Om Prakash Kant ()

For Appellant: Mr. Rajjev KhandelwalFor Respondent: 18/11/2025
Section 132(1)Section 143(3)Section 153ASection 263

interest of could not be held to be erroneous and prejudicial to interest of could not be held to be erroneous and prejudicial to interest of revenue when Assessing Officer could n revenue when Assessing Officer could not have travelled beyond ot have travelled beyond issues forming subject matter

VIIKING MEDIA AND ENTERTAINMENT PVT. LTD.,MUMBAI vs. DCIT- CENTRAL CIRCLE 2(2), MUMBAI CITY

In the result, all the appeals of the assessee are dismissed

ITA 3414/MUM/2025[2017-18]Status: DisposedITAT Mumbai20 Jan 2026AY 2017-18

Bench: Shri Sandeep Gosain () & Shri Om Prakash Kant ()

For Appellant: Mr. Rajjev KhandelwalFor Respondent: 18/11/2025
Section 132(1)Section 143(3)Section 153ASection 263

interest of could not be held to be erroneous and prejudicial to interest of could not be held to be erroneous and prejudicial to interest of revenue when Assessing Officer could n revenue when Assessing Officer could not have travelled beyond ot have travelled beyond issues forming subject matter

BADRI SINGH SISODIYA,INDORE vs. PCIT, INDORE

Appeals are dismissed

ITA 395/IND/2024[2017-18]Status: DisposedITAT Indore16 Jan 2026AY 2017-18

Bench: Shri B.M. Biyani & Shri Paresh M. Joshi

Section 147Section 263

erroneous and prejudicial to the interest of revenue. The Appellant prays that the assessment be held to be not erroneous and prejudicial to interest of revenue and consequently the revision order under section 263 be quashed. 3. On the facts and circumstances of the case and in law the learned ... PCIT erred in considering the assessment order passed by Ld. AO as erroneous and prejudicial to interest to revenue in respect of debatable issue having difference of opinion. The appellant prays that the order of commissioner passed to be directed to be set aside. 4. On the facts and circumstances

BADRI SINGH SISODIYA,INDORE vs. PCIT, INDORE

Appeals are dismissed

ITA 394/IND/2024[2014-15]Status: DisposedITAT Indore16 Jan 2026AY 2014-15

Bench: Shri B.M. Biyani & Shri Paresh M. Joshi

Section 147Section 263

erroneous and prejudicial to the interest of revenue. The Appellant prays that the assessment be held to be not erroneous and prejudicial to interest of revenue and consequently the revision order under section 263 be quashed. 3. On the facts and circumstances of the case and in law the learned ... PCIT erred in considering the assessment order passed by Ld. AO as erroneous and prejudicial to interest to revenue in respect of debatable issue having difference of opinion. The appellant prays that the order of commissioner passed to be directed to be set aside. 4. On the facts and circumstances

BADRI SINGH SISODIYA,INDORE vs. PCIT, INDORE

ITA 393/IND/2024[2013-14]Status: DisposedITAT Indore16 Jan 2026AY 2013-14
Section 147Section 263

erroneous and prejudicial to the\ninterest of revenue. The Appellant prays that the assessment be held to be\nnot erroneous and prejudicial to interest of revenue and consequently the\nrevision order under section 263 be quashed.\n\n3. On the facts and circumstances of the case ... learned PCIT\nerred in considering the assessment order passed by Ld. AO as erroneous\nand prejudicial to interest to revenue in respect of debatable issue having\ndifference of opinion. The appellant prays that the order of commissioner\npassed to be directed to be set aside.\n\n4. On the facts

WARDHA SOLAR (MAHARASHTRA) PRIVATE LIMITED,GANDHINAGAR vs. THE PR. CIT, AHMEDABAD-3, AHMEDABAD

The appeal of the assessee is dismissed

ITA 1236/AHD/2025[2020-21]Status: DisposedITAT Ahmedabad08 Jan 2026AY 2020-21

Bench: Shri Tr Senthil Kumar & Shri Narendra Prasad Sinhaassessment Year: 2020-21 Wardha Solar (Maharashtra) Principal Commissioner Of Private Limited Income Tax, Adani Corporate House, Ahmedabad - 380015 Shantigram Near Vaishnodevi Vs. Circle, Sg Highway, Khodiyar, Gandhi Nagar - 382421 [Pan – Aabcw 7314 K] (Appellant) (Respondent) Assessee By Shri S.N. Soparkar, Sr. Advocate & Ms. Ukti Shah, Ars Revenue By Shri Rignesh Das, Cit-Dr Date Of Hearing 17.12.2025 Date Of Pronouncement 08.01.2026 O R D E R

Section 143(3)Section 263Section 36(1)(III)

appellant, the Ld PCIT has erred in holding that assessment order passed u/s 143(3) r.w.s 144B on 13/09/2022 is erroneous and prejudicial to interest of revenue and set aside such order u/s 263 of the Act. 3. In law and in the facts and the circumstances of the case ... appellant, the Ld. PCIT has erred in holding that assessment order is erroneous and prejudicial to interest of revenue and directing the AO to examine allowability of claim of exceptional item of Rs. 57.02 crore when no such direction is required. 4. The appellant craves leave to add, alter

THIRUVANANTHAPURAM ROAD DEVELOPMENT COMPANY LIMITED ,MUMBAI vs. PCIT - 6, MUMBAI

ITA 2778/MUM/2025[2020-21]Status: DisposedITAT Mumbai06 Jan 2026AY 2020-21

Bench: Shri Anikesh Banerjee & Shri Jagadishassessment Year: 2020-21

For Appellant: Shri Madhur AgrawalFor Respondent: Shri Ritesh Misra, CIT DR
Section 142(1)Section 143(3)Section 263

facts and circumstances of the case and in law, the Pr. CIT erred in holding that the assessment order is erroneous and prejudicial to interest of revenue on the issue of claim of depreciation even though the claim is allowed in Tribunal decision in appellant's own case

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