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“lack of enquiry”

Rectification & RevisionSection 263Section 263780 judgments

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

Leading authorities on lack of enquiry

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. 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.

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.

CIT v. Anil Kumar Sharma
335 ITR 83 · 2011 · High Court
264
citing judgments

The Commissioner cannot invoke Section 263 for an assessment merely because of an inadequate inquiry by the Assessing Officer, provided there was some inquiry or the record demonstrates application of mind, as this constitutes a mere difference of opinion.

Narayan Tatu Rane v. ITO
70 Taxmann.com 227 · 2016 · ITAT
220
citing judgments

Before revising an assessment order under Section 263, the CIT/PCIT must conduct their own inquiries or verifications to establish that the Assessing Officer's order is erroneous and unsustainable in law, rather than merely directing further inquiry or pointing out the AO's lack of inquiry.

DIT v. Jyoti Foundation
357 ITR 388 · 2013 · High Court
210
citing judgments

An assessment order cannot be deemed erroneous and prejudicial to the interest of revenue under Section 263 if the Assessing Officer conducted an inquiry and applied their mind during the original assessment, as Explanation 2 to Section 263 does not permit unending inquiries by the revisional authority.

CIT v. Infosys Technologies Ltd.
341 ITR 293 · 2012 · High Court
205
citing judgments

A Commissioner can revise an assessment order under Section 263 if it is erroneous and prejudicial to the interests of the revenue. This includes cases where the Assessing Officer fails to make further inquiries before accepting the assessee's statements in the return.

Judgments citing lack of enquiry

ITO, Ward-1(1), Faridabad vs. Chaman, Faridabad

In the result, appeal of the assessee is allowed

ITA 2774/DEL/2024[2017-18]Status: DisposedITAT Delhi25 Jun 2025AY 2017-18

Bench: Shri Satbeer Singh Godara & Shri S. Rifaur Rahmanassessment Year: 2017-18 Vs. Chaman, Income Tax Officer, Ward-1(1), H. No. 437, Sector-9, Faridabad Faridabad Pan: Bfapd6698P (Appellant) (Respondent) With C.O. No.103/Del/2024 [Arising Out Of Ita No.2774/Del/2024] Assessment Year: 2017-18 Vs. Income Tax Officer, Chaman, H. No. 437, Sector-9, Ward-1(1), Faridabad, Haryana Faridabad Pan: Bfapd6698P (Appellant) (Respondent) Assessee By Sh. Gaurav, Adv. Department By Sh. Rajesh Kumar Dhanesta, Sr. Dr Date Of Hearing 25.06.2025 Date Of Pronouncement 25.06.2025 Order Per Satbeer Singh Godara, Jm This Revenue’S Appeal Ita No. 2774/Del/2024 & Assessee’S Cross Objection C.O. No. 103/Del/2024 For Assessment Year 2017- 18, Arises Against The Commissioner Of Income Tax (Appeals)/National Faceless Appeal Centre [In Short, The

Section 147Section 250(4)

which he ought to have carried out in respect of the enhanced compensation received by the assessee. It is not a case of 'lack of enquiry'. Merely because in his order the Ld. AO did not make elaborate discussion but was satisfied with the explanation of the assessee, the order ... evidence available on records, it cannot be alleged as done by the Ld. PCIT that it is a case of 'no enquiry' or 'lack of enquiry'. No doubt that the Ld. AO did not discuss elaborately in the assessment order but that alone cannot make the order erroneous as held

Hari Singh, Palwal vs. ITO, Ward-1(3), Faridabad

In the result, appeal of the assessee is allowed

ITA 4082/DEL/2024[2019-20]Status: DisposedITAT Delhi23 Jun 2025AY 2019-20

Bench: Shri Satbeer Singh Godara & Shri S. Rifaur Rahman

Section 142(1)Section 143Section 143(1)(a)Section 143(2)Section 143(3)Section 263Section 28Section 56(2)(viii)Section 57

which he ought to have carried out in respect of the enhanced compensation received by the assessee. It is not a case of 'lack of enquiry'. Merely because in his order the Ld. AO did not make elaborate discussion but was satisfied with the explanation of the assessee, the order ... evidence available on records, it cannot be alleged as done by the Ld. PCIT that it is a case of 'no enquiry' or 'lack of enquiry'. No doubt that the Ld. AO did not discuss elaborately in the assessment order but that alone cannot make the order erroneous as held

Polynova Industries Limited, Mumbai vs. DCIT 14(1)(1), Mumbai

In the result, the appeal of the assessee stands allowed

ITA 2982/MUM/2025[2020-21]Status: DisposedITAT Mumbai19 Jun 2025AY 2020-21

Bench: Shri Om Prakash Kant () & Shri Raj Kumar Chauhan () Assessment Year: 2020-21 Polynova Industries Limited Dcit 14(1)(1) 159, Cst Road, Kalina, Aayakar Bhavan,4Th Floor, Santacruz East, Vs. Mumbai- 400001 Mumbai- 400098 Pan No. Aabcl 0864 D Appellant Respondent

For Appellant: Mr. Rajan Vora &For Respondent: Mr. R. A. Dhyani, CIT-DR
Section 143(1)Section 143(3)Section 263Section 80G

expenditure. The learned PCIT, invoking Explanation 2 to section 263 of the Act, which deems an order as erroneous where there is a lack of enquiry or inadequate enquiry, issued a show cause notice under section 263 of the Act. Polynova Industries Limited 4 2.3 In response, the assessee submitted ... issue now sought to be revised, and hence, the invocation of Explanation 2 to section 263 of the Act—on the ground of lack of enquiry or inadequate enquiry—was unwarranted. It was further submitted that the issue under consideration is one on which two views are reasonably possible

Haresh Kumar Lalwani, Vizianagaram vs. The Principal Commissioner of Income Tax-1, Vishakhapatnam

In the result, appeal of the assessee is allowed

ITA 264/VIZ/2025[2021-22]Status: DisposedITAT Visakhapatnam17 Jun 2025AY 2021-22

Bench: Shri V. Durga Rao, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपीलसं./I.T.A. No.264/Viz/2025 (निर्धारण वर्ा/ Assessment Year: 2021-22) Haresh Kumar Lalwani V. Pr.Cit -1 22-1-22, Ambati Satram Junction Aayakar Bhavan, Daba Gardens Vizianagaram – 535002 Visakhapatnam – 530020 Andhra Pradesh Andhra Pradesh [Pan: Aaqpt9248P] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent)

Section 143(3)Section 263Section 56(2)(x)Section 69A

calling all the details and examining the same, assessment was completed. Therefore, the order passed by the Ld. AO cannot be said that lack of enquiry and further examination is not required and submitted that order passed under section 263 is invalid. 9. On the other hand, Ld. Departmental Representative ... both the issues. On very same issue, the Ld.Pr.CIT has invoked 263 proceedings and he came to the conclusion that there is a lack of enquiry by the Ld. AO and the order passed by the Ld. AO is erroneous and prejudicial to the interest of the revenue and directed

Upenkumar Amrutji Vihol, Vadodara vs. The ITO, Ward-3(1)(2)(Previously ITO, Ward-1, Anand), Vadodara

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

ITA 556/AHD/2025[2016-17]Status: DisposedITAT Ahmedabad16 Jun 2025AY 2016-17

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

For Appellant: Shri Manan Agrawal, A.RFor Respondent: Shri Sher Singh, CIT-DR & Shri Hargovind
Section 132Section 147Section 148Section 271(1)(c)Section 271FSection 69A

their respective orders. 8. On going through the facts of the instant case, we observe that apparently, there was an evident lack of enquiry made by the Tax Authorities, while concluding the assessment. When the notice of hearing was issued by the Assessing Officer, the assessee had promptly submitted that

Upenkumar Amrutji Vihol, Vadodara vs. The ITO, Ward-3(1)(2)(Previously ITO, Ward-1, Anand), Vadodara

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

ITA 555/AHD/2025[2016-17]Status: DisposedITAT Ahmedabad16 Jun 2025AY 2016-17

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

For Appellant: Shri Manan Agrawal, A.RFor Respondent: Shri Sher Singh, CIT-DR & Shri Hargovind
Section 132Section 147Section 148Section 271(1)(c)Section 271FSection 69A

their respective orders. 8. On going through the facts of the instant case, we observe that apparently, there was an evident lack of enquiry made by the Tax Authorities, while concluding the assessment. When the notice of hearing was issued by the Assessing Officer, the assessee had promptly submitted that

Upenkumar Amrutji Vihol, Vadodara vs. The ITO, Ward-3(1)(2), Vadodara

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

ITA 554/AHD/2025[2016-17]Status: DisposedITAT Ahmedabad16 Jun 2025AY 2016-17

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

For Appellant: Shri Manan Agrawal, A.RFor Respondent: Shri Sher Singh, CIT-DR & Shri Hargovind
Section 132Section 147Section 148Section 271(1)(c)Section 271FSection 69A

their respective orders. 8. On going through the facts of the instant case, we observe that apparently, there was an evident lack of enquiry made by the Tax Authorities, while concluding the assessment. When the notice of hearing was issued by the Assessing Officer, the assessee had promptly submitted that

Alliance Nirmaan Limited, Bareilly vs. PCIT, Bareilly

In the result, the appeal of the assessee is allowed

ITA 119/LKW/2022[2017-18]Status: DisposedITAT Lucknow12 Jun 2025AY 2017-18

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

Section 143(3)Section 263

issues mentioned in his show cause notice and after making due enquiries, and thus the case was not the one of lack of enquiry by the Assessing officer. 4. Grounds No. 4: The Learned PCIT, Bareilly erred in law as well as on the facts of the case in wrongly ... considerations; and therefore unsustainable. 7. Grounds No. 7: That the Learned PCIT, Bareilly has erred in holding that it is a case of "lack of enquiry" and, further failing to appreciate that alleged inadequate enquiry in the manner suggested without any independent evidence and, without any further enquiries

Paras Rameshchandra Doshi, Rajkot vs. The PCIT - 1, Rajkot

ITA 280/RJT/2024[2013-14]Status: DisposedITAT Rajkot11 Jun 2025AY 2013-14
Section 115BSection 132Section 133ASection 139(1)Section 143(2)Section 147Section 148Section 263Section 69A

replies and thereafter allowed the expenditure on tools and dyes as revenue expenditure, it cannot be said that it is a case of 'lack of enquiry' and, therefore, the assessment order passed by the AO allowing deduction of said expenditure could not be revised under s. 263 more

Mahansaria Enterprises Pvt Ltd, Mumbai vs. Pr. CIT, Mumbai-5, Mumbai

In the result, the appeal of the assessee is allowed

ITA 2158/MUM/2025[2020-21]Status: DisposedITAT Mumbai11 Jun 2025AY 2020-21

Bench: Shri Vikram Singh Yadav & Shri Rahul Chaudharyassessment Year : 2020-21 Mahansaria Enterprises Private The Principal Commissioner Of Limited, Income Tax (Pcit), 301-304, 3Rd Floor, Vs. Room No. 515, 5Th Floor, Peninsula Chambers, Aayakar Bhavan, Peninsula Corporate Park, Maharshi Karve Road, G.K. Marg, Lower Parel West, Mumbai-400020 Mumbai-400026 Pan : Aaacy1568L (Appellant) (Respondent) For Assessee : Shri Vipul Joshi, Adv. & Prashant Bhumare For Revenue : Shri Satyaprakash R. Singh, Cit-Dr Date Of Hearing : 14-05-2025 Date Of Pronouncement : 11-06-2025 O R D E R Per Vikram Singh Yadav, A.M : This Is An Appeal Filed By The Assessee Against The Order Of The Ld. Principal Commissioner Of Income Tax, Mumbai-5 [„Ld.Pcit‟] U/S. 263 Of The Income Tax Act, 1961 („The Act‟), Dated 17-03-2025, Pertaining To Assessment Year (Ay) 2020-21, Wherein The Assessee Has Taken The Following Grounds Of Appeal:

For Appellant: Shri Vipul Joshi, Adv. &For Respondent: Shri Satyaprakash R. Singh, CIT-DR
Section 143(3)Section 263Section 37(1)Section 80G

IN THE INCOME TAX APPELLATE TRIBUNAL MUMBAI “B” BENCH : MUMBAI BEFORE SHRI VIKRAM SINGH YADAV, ACCOUNTANT MEMBER AND SHRI RAHUL

Satishbhai Mohanbhai Zalavadia, Na vs. Ari, Vs.the Principal Commissioner of Income Tax, Rajkot-1, Rajkot

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

ITA 122/RJT/2022[2017-18]Status: DisposedITAT Rajkot10 Jun 2025AY 2017-18

Bench: Dr. A.L. Saini, Am & Shri Dinesh Mohan Sinha, Jm आयकर अपील सं./Ita No.122/Rjt/2022 ("नधा"रण वष" / Assessment Year: (2017-18) (Physical He Aring) Satishbhai Mohanbhai Zalavadia, The Pr. Cit – 1, Vs. 2622, Sarvoday Park, Khundh Rajkot Khundh, Chikhli, Navsari - 396521 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Acnpp0527F (Appellant) (Respondent) Appellant By : Shri Rajendra Singhal, Ar Respondent By : Shri Shramdeep Sinha, Cit-Dr Date Of Hearing : Heard On 23/07/2024 & Refix For Clarification On 24.04.2025

For Appellant: Shri Rajendra Singhal, ARFor Respondent: Shri Shramdeep Sinha, CIT-DR
Section 143(2)Section 143(3)Section 263

assessment order passed by him could not be held to be erroneous and prejudicial to the interests of revenue. There is difference between ‘Lack of enquiry’ and ‘inadequate enquiry’. It is for the AO to decide the extent of enquiry to be made as it is his satisfaction as what

Anand Boddapaty, Hyderabad vs. DCIT., Circle-5(1), Hyderabad

In the result, appeal of the Assessee is dismissed

ITA 375/HYD/2025[2021-22]Status: DisposedITAT Hyderabad09 Jun 2025AY 2021-22

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

For Appellant: CA Kumar Pal TatedFor Respondent: Sri Narender Kumar Naik
Section 142(1)Section 143(2)Section 263Section 45Section 54Section 54F

claim in light of un-registered sale deed for purchase of property from related party [wife]. Therefore, it is a clear case of lack of enquiry by the Assessing Officer on the issue in light of relevant provisions of the Act which render the assessment order erroneous and prejudicial

Income Tax Officer, Panipat vs. Dinesh Kaushik, Panipat

In the result, appeal of the assessee is allowed

ITA 5753/DEL/2024[2018-19]Status: DisposedITAT Delhi05 Jun 2025AY 2018-19

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwalassessment Year: 2018-19 Vs. Sh. Dinesh Kaushik, Income Tax Officer, Panipat Vpo Baljattan, Panipat, Haryana Pan: Awjpk9483E (Appellant) (Respondent) Assessee By None Department By Sh. Rajesh Kumar Dhanesta, Sr. Dr

Section 10(37)Section 142(1)Section 143Section 143(1)(a)Section 143(2)Section 143(3)Section 145BSection 263Section 28Section 45(5)

which he ought to have carried out in respect of the enhanced compensation received by the assessee. It is not a case of 'lack of enquiry'. Merely because in his order the Ld. AO did not make elaborate discussion but was satisfied with the explanation of the assessee, the order

Paulpandian Uthamaraj Winston, Chennai vs. PCIT, Central Circle-1, Chennai

In the result, all the appeals filed by both the assessees are allowed

ITA 425/CHNY/2025[2018-19]Status: DisposedITAT Chennai03 Jun 2025AY 2018-19

Bench: Shri S.S.Viswanethra Ravi & Shri S. R. Raghunathaआयकरअपीलसं/.Ita Nos.:418 To 421/Chny/2025 धनधाारणवर्ा / Assessment Years: 2014-15, 2015-16, 2016-17 & 2018-19 Shri Perinba Raja Ramesh, Pcit (Central) No.37, Rameswaram Road, T.Nagar, Vs. Chennai-1 Chennai-600 017. [Pan: Adfpp-5207-J] (प्रत्यथी/Respondent) (अपीलाथी/Appellant) & आयकरअपीलसं/.Ita Nos.:422 To 425/Chny/2025 धनधाारणवर्ा / Assessment Years: 2014-15, 2015-16, 2016-17 & 2018-19 Shri Paulpandianuthamaraj Pcit (Central) Winston, Vs. Chennai-1 No.37, Rameswaram Road, T.Nagar, Chennai-600 017. [Pan: Aabpu-5409-L] (प्रत्यथी/Respondent) (अपीलाथी/Appellant)

For Appellant: Shri Y.Sridhar, F.C.AFor Respondent: Ms.E.Pavuna Sundari, CIT
Section 133ASection 142(1)Section 147Section 24Section 263Section 263(1)

drawing such conclusion. 10. In the case under consideration, when the ld.Pr. CIT has formed an opinion that it is a case of lack of enquiry, directing the AO to undertake such enquiry once :-6-: ITA. Nos.:418 to 425 /Chny/2025 again is rather based on „reason to suspect ... rental income offered in the returns filed prior to the action under Section 133A, it cannot be said that there was a total lack of enquiry while concluding the assessment proceedings. 16. Even if it were an error on part of the AO to have missed out to check

Paulpandian Uthamaraj Winston, Chennai vs. PCIT, Central Circle-1, Chennai

In the result, all the appeals filed by both the assessees are allowed

ITA 424/CHNY/2025[2016-17]Status: DisposedITAT Chennai03 Jun 2025AY 2016-17

Bench: Shri S.S.Viswanethra Ravi & Shri S. R. Raghunathaआयकरअपीलसं/.Ita Nos.:418 To 421/Chny/2025 धनधाारणवर्ा / Assessment Years: 2014-15, 2015-16, 2016-17 & 2018-19 Shri Perinba Raja Ramesh, Pcit (Central) No.37, Rameswaram Road, T.Nagar, Vs. Chennai-1 Chennai-600 017. [Pan: Adfpp-5207-J] (प्रत्यथी/Respondent) (अपीलाथी/Appellant) & आयकरअपीलसं/.Ita Nos.:422 To 425/Chny/2025 धनधाारणवर्ा / Assessment Years: 2014-15, 2015-16, 2016-17 & 2018-19 Shri Paulpandianuthamaraj Pcit (Central) Winston, Vs. Chennai-1 No.37, Rameswaram Road, T.Nagar, Chennai-600 017. [Pan: Aabpu-5409-L] (प्रत्यथी/Respondent) (अपीलाथी/Appellant)

For Appellant: Shri Y.Sridhar, F.C.AFor Respondent: Ms.E.Pavuna Sundari, CIT
Section 133ASection 142(1)Section 147Section 24Section 263Section 263(1)

drawing such conclusion. 10. In the case under consideration, when the ld.Pr. CIT has formed an opinion that it is a case of lack of enquiry, directing the AO to undertake such enquiry once :-6-: ITA. Nos.:418 to 425 /Chny/2025 again is rather based on „reason to suspect ... rental income offered in the returns filed prior to the action under Section 133A, it cannot be said that there was a total lack of enquiry while concluding the assessment proceedings. 16. Even if it were an error on part of the AO to have missed out to check

Paulpandian Uthamaraj Winston, Chennai vs. PCIT, Central Circle-1, Chennai

In the result, all the appeals filed by both the assessees are allowed

ITA 423/CHNY/2025[2015-16]Status: DisposedITAT Chennai03 Jun 2025AY 2015-16

Bench: Shri S.S.Viswanethra Ravi & Shri S. R. Raghunathaआयकरअपीलसं/.Ita Nos.:418 To 421/Chny/2025 धनधाारणवर्ा / Assessment Years: 2014-15, 2015-16, 2016-17 & 2018-19 Shri Perinba Raja Ramesh, Pcit (Central) No.37, Rameswaram Road, T.Nagar, Vs. Chennai-1 Chennai-600 017. [Pan: Adfpp-5207-J] (प्रत्यथी/Respondent) (अपीलाथी/Appellant) & आयकरअपीलसं/.Ita Nos.:422 To 425/Chny/2025 धनधाारणवर्ा / Assessment Years: 2014-15, 2015-16, 2016-17 & 2018-19 Shri Paulpandianuthamaraj Pcit (Central) Winston, Vs. Chennai-1 No.37, Rameswaram Road, T.Nagar, Chennai-600 017. [Pan: Aabpu-5409-L] (प्रत्यथी/Respondent) (अपीलाथी/Appellant)

For Appellant: Shri Y.Sridhar, F.C.AFor Respondent: Ms.E.Pavuna Sundari, CIT
Section 133ASection 142(1)Section 147Section 24Section 263Section 263(1)

drawing such conclusion. 10. In the case under consideration, when the ld.Pr. CIT has formed an opinion that it is a case of lack of enquiry, directing the AO to undertake such enquiry once :-6-: ITA. Nos.:418 to 425 /Chny/2025 again is rather based on „reason to suspect ... rental income offered in the returns filed prior to the action under Section 133A, it cannot be said that there was a total lack of enquiry while concluding the assessment proceedings. 16. Even if it were an error on part of the AO to have missed out to check

Paulpandian Uthamaraj Winston, Chennai vs. PCIT, Central Circle-1, Chennai

In the result, all the appeals filed by both the assessees are allowed

ITA 422/CHNY/2025[2014-15]Status: DisposedITAT Chennai03 Jun 2025AY 2014-15

Bench: Shri S.S.Viswanethra Ravi & Shri S. R. Raghunathaआयकरअपीलसं/.Ita Nos.:418 To 421/Chny/2025 धनधाारणवर्ा / Assessment Years: 2014-15, 2015-16, 2016-17 & 2018-19 Shri Perinba Raja Ramesh, Pcit (Central) No.37, Rameswaram Road, T.Nagar, Vs. Chennai-1 Chennai-600 017. [Pan: Adfpp-5207-J] (प्रत्यथी/Respondent) (अपीलाथी/Appellant) & आयकरअपीलसं/.Ita Nos.:422 To 425/Chny/2025 धनधाारणवर्ा / Assessment Years: 2014-15, 2015-16, 2016-17 & 2018-19 Shri Paulpandianuthamaraj Pcit (Central) Winston, Vs. Chennai-1 No.37, Rameswaram Road, T.Nagar, Chennai-600 017. [Pan: Aabpu-5409-L] (प्रत्यथी/Respondent) (अपीलाथी/Appellant)

For Appellant: Shri Y.Sridhar, F.C.AFor Respondent: Ms.E.Pavuna Sundari, CIT
Section 133ASection 142(1)Section 147Section 24Section 263Section 263(1)

drawing such conclusion. 10. In the case under consideration, when the ld.Pr. CIT has formed an opinion that it is a case of lack of enquiry, directing the AO to undertake such enquiry once :-6-: ITA. Nos.:418 to 425 /Chny/2025 again is rather based on „reason to suspect ... rental income offered in the returns filed prior to the action under Section 133A, it cannot be said that there was a total lack of enquiry while concluding the assessment proceedings. 16. Even if it were an error on part of the AO to have missed out to check

Perinba Raja Ramesh, Chennai vs. PCIT, Central Circle-1, Chennai

In the result, all the appeals filed by both the assessees are allowed

ITA 421/CHNY/2025[2018-19]Status: DisposedITAT Chennai03 Jun 2025AY 2018-19

Bench: Shri S.S.Viswanethra Ravi & Shri S. R. Raghunathaआयकरअपीलसं/.Ita Nos.:418 To 421/Chny/2025 धनधाारणवर्ा / Assessment Years: 2014-15, 2015-16, 2016-17 & 2018-19 Shri Perinba Raja Ramesh, Pcit (Central) No.37, Rameswaram Road, T.Nagar, Vs. Chennai-1 Chennai-600 017. [Pan: Adfpp-5207-J] (प्रत्यथी/Respondent) (अपीलाथी/Appellant) & आयकरअपीलसं/.Ita Nos.:422 To 425/Chny/2025 धनधाारणवर्ा / Assessment Years: 2014-15, 2015-16, 2016-17 & 2018-19 Shri Paulpandianuthamaraj Pcit (Central) Winston, Vs. Chennai-1 No.37, Rameswaram Road, T.Nagar, Chennai-600 017. [Pan: Aabpu-5409-L] (प्रत्यथी/Respondent) (अपीलाथी/Appellant)

For Appellant: Shri Y.Sridhar, F.C.AFor Respondent: Ms.E.Pavuna Sundari, CIT
Section 133ASection 142(1)Section 147Section 24Section 263Section 263(1)

drawing such conclusion. 10. In the case under consideration, when the ld.Pr. CIT has formed an opinion that it is a case of lack of enquiry, directing the AO to undertake such enquiry once :-6-: ITA. Nos.:418 to 425 /Chny/2025 again is rather based on „reason to suspect ... rental income offered in the returns filed prior to the action under Section 133A, it cannot be said that there was a total lack of enquiry while concluding the assessment proceedings. 16. Even if it were an error on part of the AO to have missed out to check

Perinba Raja Ramesh, Chennai vs. PCIT, Central Circle-1, Chennai

In the result, all the appeals filed by both the assessees are allowed

ITA 420/CHNY/2025[2016-17]Status: DisposedITAT Chennai03 Jun 2025AY 2016-17

Bench: Shri S.S.Viswanethra Ravi & Shri S. R. Raghunathaआयकरअपीलसं/.Ita Nos.:418 To 421/Chny/2025 धनधाारणवर्ा / Assessment Years: 2014-15, 2015-16, 2016-17 & 2018-19 Shri Perinba Raja Ramesh, Pcit (Central) No.37, Rameswaram Road, T.Nagar, Vs. Chennai-1 Chennai-600 017. [Pan: Adfpp-5207-J] (प्रत्यथी/Respondent) (अपीलाथी/Appellant) & आयकरअपीलसं/.Ita Nos.:422 To 425/Chny/2025 धनधाारणवर्ा / Assessment Years: 2014-15, 2015-16, 2016-17 & 2018-19 Shri Paulpandianuthamaraj Pcit (Central) Winston, Vs. Chennai-1 No.37, Rameswaram Road, T.Nagar, Chennai-600 017. [Pan: Aabpu-5409-L] (प्रत्यथी/Respondent) (अपीलाथी/Appellant)

For Appellant: Shri Y.Sridhar, F.C.AFor Respondent: Ms.E.Pavuna Sundari, CIT
Section 133ASection 142(1)Section 147Section 24Section 263Section 263(1)

drawing such conclusion. 10. In the case under consideration, when the ld.Pr. CIT has formed an opinion that it is a case of lack of enquiry, directing the AO to undertake such enquiry once :-6-: ITA. Nos.:418 to 425 /Chny/2025 again is rather based on „reason to suspect ... rental income offered in the returns filed prior to the action under Section 133A, it cannot be said that there was a total lack of enquiry while concluding the assessment proceedings. 16. Even if it were an error on part of the AO to have missed out to check

Perinba Raja Ramesh, Chennai vs. PCIT, Central Circle-1, Chennai

In the result, all the appeals filed by both the assessees are allowed

ITA 419/CHNY/2025[2015-16]Status: DisposedITAT Chennai03 Jun 2025AY 2015-16

Bench: Shri S.S.Viswanethra Ravi & Shri S. R. Raghunathaआयकरअपीलसं/.Ita Nos.:418 To 421/Chny/2025 धनधाारणवर्ा / Assessment Years: 2014-15, 2015-16, 2016-17 & 2018-19 Shri Perinba Raja Ramesh, Pcit (Central) No.37, Rameswaram Road, T.Nagar, Vs. Chennai-1 Chennai-600 017. [Pan: Adfpp-5207-J] (प्रत्यथी/Respondent) (अपीलाथी/Appellant) & आयकरअपीलसं/.Ita Nos.:422 To 425/Chny/2025 धनधाारणवर्ा / Assessment Years: 2014-15, 2015-16, 2016-17 & 2018-19 Shri Paulpandianuthamaraj Pcit (Central) Winston, Vs. Chennai-1 No.37, Rameswaram Road, T.Nagar, Chennai-600 017. [Pan: Aabpu-5409-L] (प्रत्यथी/Respondent) (अपीलाथी/Appellant)

For Appellant: Shri Y.Sridhar, F.C.AFor Respondent: Ms.E.Pavuna Sundari, CIT
Section 133ASection 142(1)Section 147Section 24Section 263Section 263(1)

drawing such conclusion. 10. In the case under consideration, when the ld.Pr. CIT has formed an opinion that it is a case of lack of enquiry, directing the AO to undertake such enquiry once :-6-: ITA. Nos.:418 to 425 /Chny/2025 again is rather based on „reason to suspect ... rental income offered in the returns filed prior to the action under Section 133A, it cannot be said that there was a total lack of enquiry while concluding the assessment proceedings. 16. Even if it were an error on part of the AO to have missed out to check