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“assessment order erroneous”

Rectification & RevisionSection 263Section 263534 judgments

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

Leading authorities on assessment order erroneous

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.

Parashuram Pottery Works Co. Ltd. v. ITO
106 ITR 1 · 1977 · Supreme Court
486
citing judgments

The principle of finality dictates that stale issues should not be reactivated, and lapse of time brings repose to judicial and quasi-judicial controversies. A Commissioner cannot substitute their judgment for the Assessing Officer's unless the assessment order is legally erroneous, not merely less elaborate, thus limiting revisionary powers under Section 263.

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.

Judgments citing assessment order erroneous

Kalpeshbhai Savani, Ahmedabad vs. The PCIT-3, Ahmedabad

In the result, the appeals of the assessee are allowed for all the assessment years before us

ITA 1048/AHD/2024[2016-17]Status: DisposedITAT Ahmedabad06 Dec 2024AY 2016-17

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

Section 147Section 263

Ld.PCIT has not given any specific findings or observation nor has pointed any defect in the assessment order so as to make the assessment order erroneous and prejudicial to the interest of Revenue. Further, there is also no specific observation in 263 order that there was any lack of inquiry

Paresh Nagjibhai Vahanka, Ahmedabad vs. The PCIT-3, Ahmedabad

In the result, the appeals of the assessee are allowed for all the assessment years before us

ITA 1047/AHD/2024[2016-17]Status: DisposedITAT Ahmedabad06 Dec 2024AY 2016-17

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

Section 147Section 263

Ld.PCIT has not given any specific findings or observation nor has pointed any defect in the assessment order so as to make the assessment order erroneous and prejudicial to the interest of Revenue. Further, there is also no specific observation in 263 order that there was any lack of inquiry

Ramjibhai Ghilabhai Vaghasiya, Ahmedabad vs. The Prcit-3, Ahmedabad

In the result, the appeals of the assessee are allowed for all the assessment years before us

ITA 1046/AHD/2024[2016-17]Status: DisposedITAT Ahmedabad06 Dec 2024AY 2016-17

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

Section 147Section 263

Ld.PCIT has not given any specific findings or observation nor has pointed any defect in the assessment order so as to make the assessment order erroneous and prejudicial to the interest of Revenue. Further, there is also no specific observation in 263 order that there was any lack of inquiry

Manojbhai Padaliya, Ahmedabad vs. The PCIT-3, Ahmedabad

In the result, the appeals of the assessee are allowed for all the assessment years before us

ITA 1045/AHD/2024[2013-14]Status: DisposedITAT Ahmedabad06 Dec 2024AY 2013-14

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

Section 147Section 263

Ld.PCIT has not given any specific findings or observation nor has pointed any defect in the assessment order so as to make the assessment order erroneous and prejudicial to the interest of Revenue. Further, there is also no specific observation in 263 order that there was any lack of inquiry

Priya Construction, Namakkal vs. PCIT, Central, Chennai-2

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

ITA 1622/CHNY/2024[2019-20]Status: DisposedITAT Chennai04 Dec 2024AY 2019-20

Bench: Shri Aby T. Varkey & Shri Jagadish

For Appellant: Mr.S. Sridhar, AdvocateFor Respondent: Mr. Nilay Baran Som, CIT
Section 133ASection 143(3)Section 263

assess the "other income" in the manner described above. In view of these facts this becomes an error of omission and renders the assessment order erroneous and prejudicial to revenue. 8. The assessment order is squarely covered by the decision of the Hon'ble Delhi High Court in the case ... income shown separately by the assessee to the tune of Rs.43,60,829/- which omission on the part of the AO makes the assessment order erroneous as well as prejudicial to the Revenue; and after hearing the assessee, the Ld.PCIT has passed the impugned order M/s. Priya Construction :: 9 :: directing

Chaitalee Sachin Deokar, Mumbai vs. Commissioner of Income Tax, -It -2, Mumbai

In the result, both the appeals filed by the assessee are

ITA 2806/MUM/2024[2013-14]Status: DisposedITAT Mumbai04 Dec 2024AY 2013-14

Bench: Shri Sandeep Gosain & Ms. Padmavathy S

Section 143(3)Section 263Section 69Section 69BSection 69C

supra) to contend that non-application of mind on the part of the AO on the facts collected would render the assessment order erroneous. He further submitted that omission on the part of the assessing officer to consider various factual aspects such as the date of birth of the assessee

Sonal Sandeep Satav, Pune vs. PCIT, Pune-2, Pune

In the result, the appeal of the assessee is dismissed

ITA 945/PUN/2024[2018-19]Status: DisposedITAT Pune03 Dec 2024AY 2018-19

Bench: Ms. Astha Chandra & Shree G.D. Padmahshali

For Appellant: Shri Sarang GudhateFor Respondent: Shri Ajay Kumar Keshari
Section 142(1)Section 143(2)Section 143(3)Section 263

However, since the assessee subsequently furnished the additional evidence/details before the Ld. PCIT, he should have considered the same instead of holding the assessment order erroneous and prejudicial to the interest of the Revenue and directing the Ld. AO to revise the assessment order. 8. The Finance Act, 2015 inserted

Anand Construwell Private Limited, Nashik vs. Principal Commissioner of Income Tax, Nashik -1, Nashik

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

ITA 955/PUN/2024[2019-20]Status: DisposedITAT Pune29 Nov 2024AY 2019-20

Bench: Shri R. K. Panda & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.955/Pun/2024 िनधा"रण वष" / Assessment Year: 2019-20 Anand Construwell Private Vs. Pcit-1, Nashik. Limited, Ramchandra Apartments, Makhmalabad Road, Panchvati, Nashik- 422003. Pan : Aafca7736H Appellant Respondent Assessee By : Shri Pramod S. Shingte Revenue By : Shri Keyur Patel Date Of Hearing : 05.09.2024 Date Of Pronouncement : 29.11.2024 आदेश / Order Per Vinay Bhamore, Jm: This Appeal Filed By The Assessee Is Directed Against The Order Dated 19.03.2024 Passed By Ld. Pcit-1, Nashik [‘Ld. Pcit’] For The Assessment Year 2019-20. 2. The Appellant Has Raised The Following Grounds Of Appeal :- “1. On The Basis Of The Facts & Circumstances Of The Case, The Order Passed U/S. 263 By The Principal Commissioner Of Income-Tax, Nashik May Please Be Quashed. 2. On The Basis Of The Facts & Circumstances Of The Case, The Principal Commissioner Of Income-Tax Is Not Justified In Invoking The Provisions Of Section 263 By Holding That Provisions Of Section 69C Are Applicable In The Present Case As The Assessee Was Not Able To Explain The Sources Of Expenditure

For Appellant: Shri Pramod S. ShingteFor Respondent: Shri Keyur Patel
Section 115BSection 133ASection 143(2)Section 143(3)Section 154Section 263Section 69C

hands of A.O. Therefore, it can be inferred safely that AO has failed to cause proper inquiries and consequential verifications which rendered assessment order erroneous and prejudicial to the interest of revenue. 07. In the light of the detailed discussion made hereinabove, I am of the considered opinion that

Chintamani Commodities, Jhilmil Industrial Area vs. PCIT, Delhi

ITA 2610/DEL/2024[2013-14]Status: DisposedITAT Delhi28 Nov 2024AY 2013-14

Bench: Ms. Madhumita Roy & Shri Brajesh Kumar Singhchintamani Commodities Vs. Pcit, 20 A-20, Jhilmil Industrial Room No. 106, Vikas Area, Shahdhra Bhawan, I P Estate Delhi - 110095 Delhi – 110002 "थायीलेखासं./जीआइआरसं./Pan/Gir No:Aagfc9374B Appellant .. Respondent

For Appellant: Sh. R.S. Singhvi, CA &For Respondent: Sh. Surender Pal, CIT, DR
Section 147Section 263Section 68Section 69C

Commodities Coordinate Bench in M/s Uma Glass Work (supra) therefore, squarely applicable in the case in hand. 11. Further that while holding the assessment order erroneous, without making independent inquiry by the PCIT to record such finding which ought to have been done by him setting aside the issue

The Thanthi Trust, Chennai vs. CIT(Exemptions), Chennai

In the result, the appeal of the assessee is allowed

ITA 1369/CHNY/2024[2018-19]Status: DisposedITAT Chennai26 Nov 2024AY 2018-19

Bench: Shri Aby T Varkey, Hon’Ble & Shri S.R.Raghunatha, Hon’Bleआयकरअपीलसं./Ita No.: 1369/Chny/2024 िनधा"रणवष" / Assessment Year: 2018-19 Commissioner Of Income Tax The Thanthi Trust, V. (Exemptions), No. 86, Evk Sampath Road, Chennai – 600 034. Vepery, Chennai – 600 007. [Pan: Aaatt-0038-R] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ"क"ओरसे/Appellant By : Shri. V.S. Jayakumar, Sr. Advocate For Shri.Mudit Bohara, Advocate & Shri. K.R. Adivarahan, Ca ""यथ"क"ओरसे/Respondent By : Shri. Nilay Baran Som, Cit सुनवाई क" तारीख/Date Of Hearing : 30.08.2024 घोषणा क" तारीख/Date Of Pronouncement : 26.11.2024 आदेश /O R D E R

For Appellant: Shri. V.S. Jayakumar, Sr. Advocate for Shri.Mudit Bohara, Advocate and Shri. K.RFor Respondent: Shri. Nilay Baran Som, CIT
Section 11(4)Section 12ASection 143(1)Section 143(2)Section 143(3)Section 263

entire details of corpus donations, advance tax and amount paid to M/s.Metronation Chennai Television P. Ltd., and the same has resulted the assessment order erroneous and prejudicial to the interest of revenue. 7. We have heard the rival contentions and perused the material available on record. The jurisdiction

Gujarat Gas Limited, Ahmedabad vs. The Pr. CIT-3, Ahmedabad

In the result, we are of the considered view that Ld

ITA 969/AHD/2024[2018-19]Status: DisposedITAT Ahmedabad21 Nov 2024AY 2018-19

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

For Appellant: Shri S. N. Soparkar, Sr. Advocate &For Respondent: Shri A. P. Singh, CIT DR
Section 2Section 32(1)(iia)Section 35DSection 80

additional depreciation amounting to Rs. 18.89 crores and therefore, the A.O. had failed to properly examine or verify this claim, thereby making the assessment order erroneous and prejudicial to the interest of the Revenue. Regarding the assessee’s claim for deduction under Section 35DD of the Act, the PCIT ... that the A.O. erred in allowing assessee’s claim for additional depreciation under Section 32(1)(iia) of the Act, thereby making the assessment order erroneous and prejudicial to the interest of the Revenue. 11. In the result, Ground (II) of the assessee’s appeal is allowed. Ground

Priyanka Baheti, Hyderabad vs. Income Tax Officer, Ward-7(1), Hyderabad

In the result, appeal filed by the assessee is allowed

ITA 444/HYD/2024[2014-15]Status: DisposedITAT Hyderabad21 Nov 2024AY 2014-15

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Manjunatha, G. & आ.अपी.सं /Ita No.444/Hyd/2024 (िनधा"रण वष"/Assessment Year: 2014-15) Smt. Priyanka Baheti Vs. Income Tax Officer Hyderabad Ward 7 (1) Pan: Amspb86983E Hyderabad (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Advocate Siddharth Toshnival राज" व "ारा/Revenue By:: Shri B Bala Krishna, Dr सुनवाई की तारीख/Date Of Hearing: 14/11/2024 घोषणा की तारीख/Pronouncement: 21/11/2024 आदेश/Order

For Appellant: Advocate Siddharth ToshnivalFor Respondent: : Shri B Bala Krishna, DR
Section 115BSection 143(1)Section 147Section 148Section 263Section 69A

omission to do so on the part of the Assessing Officer while framing the re-assessment u/s 147 r.w.s. 144 renders the assessment order erroneous in so far as it is prejudicial to the interest of the Revenue. Accordingly, a show-cause notice

M/S Swift Vintrade Pvt. Ltd., Kolkata vs. CIT, Kolkata-1I, Kolkata

In the result, the appeal of the assessee is dismissed

ITA 1032/KOL/2014[2009-2010]Status: DisposedITAT Kolkata21 Nov 2024AY 2009-2010

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishraassessment Year: 2009-10

For Appellant: N o n eFor Respondent: Shri A. Kundu, CIT, DR
Section 143Section 148Section 263

regarding the identity and creditworthiness of the share holders and the impugned order was passed mechanically without application of mind which rendered the assessment order erroneous and prejudicial to the interest of revenue. The assessee filed a written submission on 21.02.2014. The gist of the written submission made ... issue of share capital? Where the Assessing Officer has made proper enquiry and still comes to a wrong conclusion, which renders the assessment order erroneous and prejudicial to the interest of the revenue, it becomes the duty of the Commissioner to expressly point out where the Assessing Officer went wrong

Bhagwanram Chimnaramji Prajapat, Hyderabad vs. Income Tax Officer, Ward-11(3), Hyderabad

In the result, appeal filed by the assessee is allowed

ITA 494/HYD/2019[2014-15]Status: DisposedITAT Hyderabad20 Nov 2024AY 2014-15

Bench: Shri Manjunatha, G. (Accountant Member), Shri K. Narasimha Chary (Judicial Member)

For Appellant: Shri P.Murali Mohan Rao, ARFor Respondent: : Shri K.Meghnath Chowhan
Section 143(3)Section 263

verify the issue of sundry creditors, although there are various anomalies in sundry creditors shown in the balance sheet which rendered the assessment order erroneous insofar as it is prejudicial to the interest of the Revenue. In response, the assessee vide letter dated 12/11/2018 and 16/11/2018 submitted that the sole ... contravention of provisions of section 40A(3A) of the Act. The Ld.AO without considering relevant facts, simply completed the assessment, which renders the assessment order erroneous insofar as it is prejudicial to the interest of the Revenue. Therefore, set aside the assessment order passed by the Ld.AO

Hasmukh Hirji Gada, Pune vs. PCIT (Central), Pune

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

ITA 1023/PUN/2024[2020-21]Status: DisposedITAT Pune07 Nov 2024AY 2020-21

Bench: Shri R. K. Panda & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.1023/Pun/2024 िनधा"रण वष" / Assessment Year: 2020-21 Hasmukh Hirji Gada, Vs. Pcit (Central), Pune. 1073, Bhosale Mystiqa, Plot No.425, Flat No.203, Gokhale Road, Om Super Market, Shivaji Nagar, Pune- 411002. Pan : Adxps3533L Appellant Respondent Assessee By : Shri Neelesh Khandelwal Revenue By : Shri Keyur Patel Date Of Hearing : 02.09.2024 Date Of Pronouncement : 07.11.2024 आदेश / Order Per Vinay Bhamore, Jm: This Appeal Filed By The Assessee Is Directed Against The Order Dated 11.03.2024 Passed By Ld. Pcit (Central), Pune For The Assessment Year 2020-21. 2. The Appellant Has Raised The Following Grounds Of Appeal :- “1. On The Facts & Circumstances Prevailing In The Case & As Per Provisions Of Law It Be Held That The Order Passed By The Principal Commissioner Of Income Tax Under Section 263 For Initiating The Penalty Under Section 271Aac Of The Act Is Without Jurisdiction & Hence Is Improper, Unwarranted, Unjustified & Contrary To The Provisions Of Law & Facts Prevailing In The Case. The Order Passed U/S. 263 Be Set Aside. The Appellant Be Granted Just & Proper Relief In This Respect.

For Appellant: Shri Neelesh KhandelwalFor Respondent: Shri Keyur Patel
Section 115BSection 132Section 143(3)Section 234ASection 263Section 271ASection 69A

against the provisions of the IT Act. It was also submitted that non-initiation of such penalty proceedings cannot render the assessment order erroneous or prejudicial to the interest of the revenue. In support of above 5 contention, ld. Counsel for the assessee relied on the following judgements/decisions ... held that the omission on the part of the Assessing Officer to initiate penalty proceedings during the course of assessment has rendered Assessment Orders erroneous and prejudicial to the interest of Revenue. Thus the Learned Commissioner of Income Tax directed the Assessing Officer to pass a fresh Assessment Order

Anil Dua, New Delhi vs. PCIT -10, New Delhi

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

ITA 1843/DEL/2024[2018-19]Status: DisposedITAT Delhi07 Nov 2024AY 2018-19

Bench: Shri Shamim Yahya & Ms Madhumita Royassessment Year: 2018-19 Anil Dua Vs. Pcit -10 F-13, Kailash Colony, New Delhi-110002 New Delhi-110048 Pan :Aacpd8370L (Appellant) (Respondent)

Section 142(1)Section 143(1)(a)Section 143(2)Section 143(3)Section 154Section 263Section 263(1)Section 54

been allo impugned that relief has been allowed to the assessee without making wed to the assessee without making proper inquiries/verification rendered the assessment order erroneous, in proper inquiries/verification rendered the assessment order erroneous, in proper inquiries/verification rendered the assessment order erroneous, in so far as it is prejudicial ... power under Section 263 of the Act by the PCIT on the plea of no inquiry conducted by the Assessing Officer renders the assessment order erroneous so far as it is prejudicial to the interest of the revenue is found to be incorrect. The impugned order, therefore, on the basis

Avani Petrochem Private Limited, Vadodara vs. The Pr.CIT(Central), Surat

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

ITA 1099/AHD/2024[2013-14]Status: DisposedITAT Ahmedabad01 Nov 2024AY 2013-14

Bench: Shri T.R. Senthil Kumar (Judicial Member), Shri Narendra Prasad Sinha (Accountant Member)

Section 10(2)Section 132Section 143(3)Section 14ASection 153ASection 68

IN THE INCOME TAX APPELLATE TRIBUNAL AHMEDABAD “C” BENCH Before: Shri T.R. Senthil Kumar, Judicial Member And Shri Narendra Prasad

Medisi Barkiah, Port Blair vs. PCIT-1, Kolkata

In the result, appeal of the assessee is allowed

ITA 579/KOL/2024[2019-20]Status: DisposedITAT Kolkata30 Oct 2024AY 2019-20

Bench: the Ld. Pr. CIT that source of cash found in the course of search action was from the proceeds received on sale of agricultural land, the Ld. Pr. CIT was unjustified in setting aside the assessment and directing the AO on pure surmises and conjectures which clearly shows that the assessment order was neither erroneous nor prejudicial to the interest of the Revenue.

Section 132Section 139(4)Section 143(3)Section 153ASection 263

scrutinized the assessee’s claims regarding the agricultural income and the accumulation of cash. This failure to conduct a detail enquiry rendered the assessment order erroneous and prejudicial to the interest of the revenue, justifying the invocation of section 263 of the Act. 7. We have considered the rival submissions

Gujarat Tea Processors & Packers Ltd., Ahmedabad vs. The Pr. CIT-1, Ahmedabad

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

ITA 837/AHD/2024[2018-19]Status: DisposedITAT Ahmedabad29 Oct 2024AY 2018-19

Bench: Shri Tr Senthil Kumar & Shri Narendra Prasad Sinhaआयकर अपील सं./Ita No. 837/Ahd/2024 "नधा"रण वष"/Asstt. Year: 2018-2019 Gujarat Tea Processor & Packers Principal Ltd., बनामVs Commissioner Of . Waghbakri House, Income Tax-1, Opp. Parimal Garden, Ahmedabad. Ellisbridge, Ahmedabad-380006. Pan: Aaacg5594L ( ""यथ" /Respondent) (अपीलाथ" /Appellant Assessee By : Shri Yogesh Shah, Ar Revenue By : Shri R.N Dsouza, Cit.Dr सुनवाई क" तार"ख/Date Of Hearing : 30/09/2024 घोषणा क" तार"ख /Date Of Pronouncement: 29/10/2024 आदेश/O R D E R Per Narendra Prasad Sinha, Am: This Appeal Filed By The Assessee Is Directed Against The Order Of The Ld. Pcit, Ahmedabad-1, Dated 29.02.2023 For The Assessment Year (A.Y.) 2018- 19, Passed In His Revisional Jurisdiction U/S. 263 Of The Income Tax Act (Hereinafter Referred To As “The Act”).

For Appellant: Shri Yogesh Shah, ARFor Respondent: Shri R.N Dsouza, CIT.DR
Section 143(3)Section 14ASection 263

assessee was neither explained by the assessee nor examined by the AO. The failure to carry out this exercise had made the assessment order erroneous and prejudicial to the interest of revenue. 7. The submission of the assessee before the Ld. PCIT that the disallowance u/s.14A should be restricted

T V Sundaram Iyengar & Sons Limited, Madurai vs. DCIT, CC - 2, Madurai

Appeal of the assessee stands dismissed

ITA 1803/CHNY/2019[2013-14]Status: DisposedITAT Chennai28 Oct 2024AY 2013-14

Bench: Hon’Ble Shri Manu Kumar Giri & Hon’Ble Shri S.R. Raghunathaआयकर अपील सं./Ita No.1803/Chny/2019 िनधा"रण वष"/Assessment Year:2013-2014. M/S. T.V. Sundram Iyengar & The Deputy Commissioner Sons Private Limited, Vs. Of Income Tax, No.7B, Tvs Building, Corporate Circle 2, West Veli Street. Madurai. Madurai 625 001. Pan: Aabct 0159K (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ"क"ओरसे/Appellant By : Shri N.V. Balaji, Advocate ""यथ"क"ओरसे/Respondent By : Shri. Nilay Baran Som, Irs, Cit

For Appellant: Shri N.V. Balaji, AdvocateFor Respondent: Shri. Nilay Baran Som, IRS, CIT
Section 143(3)Section 263Section 35DSection 391

reference to section 72(1) of the Income Tax Act, 1961. Therefore, such lack of enquiry and allowance of incorrect claim renders the assessment order erroneous as well as prejudicial to the interest of revenue. Submission with regard to the ‘learned PCIT failed to appreciate that the details of brought