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“inadequate enquiry”

Rectification & RevisionSection 263Section 263401 judgments

AMAZON SMART COMMERCE SOLUTIONS PRIVATE LIMITED,DELHI vs. PRINCIPAL COMMISSIONER OF INCOME TAX, DELHI-1, DELHI

In the result, grounds raised by the assessee are dismissed

ITA 3533/DEL/2025[2021-22]Status: DisposedITAT Delhi18 Mar 2026AY 2021-22
Section 143(1)Section 143(3)Section 263Section 40A(2)

view in law, which cannot be regarded as erroneous, much less prejudicial to the interests of the Revenue.\nRe (c): Lack of enquiry vs. Inadequate Enquiry\n152 It is well settled law that if the concerned officers, acting in accordance with law makes an assessment, the same could ... more enquiries ought to have been conducted to find something.\n153 There is, it is respectfully submitted, a distinction between “lack of enquiry” and “inadequate enquiry”. While in the former case, the assessment order may be regarded as “erroneous”, but that would not be so in the latter case where

CLAYMINE MICRONS LLP,WANKANER vs. PRINCIPAL CIT 1, RAJKOT

In the result, the appeal of the assessee in ITA No

ITA 216/RJT/2024[2018-19]Status: DisposedITAT Rajkot11 Mar 2026AY 2018-19

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinhaआयकर अपील सं. / Ita No. 216/Rjt/2024 Assessment Year: (2018-19) (Physical Hearing) Claymine Microns Llp Vs. Pcit Survey No. 59 At Ratavirda, Nr. Capron Aayakar Bhawan, Race Course Ceramic Sartanpar Road, Wankaner, Ring Road, Rajkot, Gujarat - Gujarat - 363641 360001 Pan/Gir No.: Aamfc4286C (Assessee) (Respondent) िनधा"रती की ओर से/Assessee By : Shri Hardik Vora, Ar राज" की ओर से/Respondent By : Shri Sanjay Punglia, Cit. Dr सुनवाई की तारीख/Date Of Hearing : 16/02/2026 घोषणा की तारीख/Date Of Pronouncement : 11/03/2026

For Appellant: Shri Hardik Vora, ARFor Respondent: Shri Sanjay Punglia, CIT. DR
Section 143(3)Section 263Section 68

capital contribution by partners. It is a very well settled position under the law that while making assessment, the assessing officer made an inadequate enquiry, that by itself, would not empower exercise of powers u/s 263 of the Act and it is only in cases of lack of inquiry

PROGRESSIVE CONSTRUCTIONS LIMITED,HYDERABAD vs. DCIT., CIRCLE-5(1), HYDERABAD

In the result, appeal of the Assessee is allowed

ITA 625/HYD/2025[2021-2022]Status: DisposedITAT Hyderabad04 Mar 2026AY 2021-2022

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdiaआ.अपी.सं /Ita.No.625/Hyd/2025 Assessment Year 2021-2022 Progressive Constructions The Dcit, Limited, Hyderabad. Circle-5(1) Vs. Pin – 500 001. Telangana. Hyderabad - 500 004. Pan Aabcp2274M Telangana. (Appellant) (Respondent) Ca Pawan Kumar Chakrapani िनधा"रती "ारा/Assessee By : & Sri Santi Pavan Kumar, Advocate राज" व "ारा/Revenue By : Sri Lv Bhaskara Reddy, Cit-Dr सुनवाई की तारीख/Date Of Hearing: 02.02.2026 घोषणा की तारीख/Pronouncement: 04.03.2026 आदेश/Order Per Vijay Pal Rao:

For Appellant: And Sri Santi Pavan Kumar, AdvocateFor Respondent: Sri LV Bhaskara Reddy, CIT-DR
Section 143(3)Section 194CSection 263Section 36(1)(vii)

Revenue and therefore, the Pr. CIT was justified in invoking the provisions of sec.263 of the Act. He has further submitted that inadequate enquiry on the part of the Assessing Officer leads to the order of the Assessing Officer as erroneous so far as prejudicial to the interest of revenue

STARSHINE LAND DEVELOPERS PRIVATE LIMITED,ANDHERI EAST, MUMBAI vs. PRINCIPAL COMMISSIONER OF INCOME TAX, MUMBAI-5, AAYAKAR BHAVAN, MUMBAI

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

ITA 2148/MUM/2024[2015-16]Status: DisposedITAT Mumbai27 Feb 2026AY 2015-16

Bench: Shri Saktijit Dey & Shri Jagadishassessment Year: 2015-16

Section 142(1)Section 143(2)Section 143(3)Section 144BSection 148Section 23(5)Section 263

order does not reflect any such application of mind. Therefore, this is a clear case of lack of enquiry and not a case of inadequate enquiry. The Hon’ble Supreme Court in PCIT vs. Paville Projects Pvt. Ltd., as relied upon by the Ld. DR, has reiterated that where

TRUHOME FINANCE LIMITED (EARLIER KNOWN AS SHRIRAM HOUSING FINANCE LIMITED),CHENNAI vs. INCOME TAX OFFICER CORPORATE WARD 3(1) CHENNAI, CHENNAI

In the result, appeal of the assessee is dismissed

ITA 781/CHNY/2025[2018-19]Status: DisposedITAT Chennai23 Feb 2026AY 2018-19
Section 143(3)Section 263Section 36

deduction u/s. 36(1)(viia). The key question for our\nconsideration is whether such enquiry was sufficient or inadequate,\nand whether an allegedly inadequate enquiry can justify revising an\nassessment order.In our view, as long as an enquiry has been\nconducted during the assessment proceedings, it cannot be\ndisregarded simply ... Commissioner of Income-tax (PCIT) issued a revision order under section 263, alleging the assessment order was erroneous and prejudicial to revenue due to inadequate enquiry regarding bad debts and excess provision write-back.", "held": "The Tribunal held that the Assessing Officer had conducted inquiries during the assessment

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

cannot remand the matter to the assessing officer to decide whether the findings recorded are erroneous. 9.2.2. In cases where there is inadequate enquiry but not lack of enquiry, again the CIT must give and record a finding that the order/enquiry made is erroneous. This can happen if an enquiry

SIDDHARTH BHASKAR SHAH,MUMBAI vs. PR. COMMISSIONER OF INCOME TAX-27, NEW MUMBAI

In the result, the appeal filed by the assessee stands\nallowed

ITA 3327/MUM/2025[2022-23]Status: DisposedITAT Mumbai16 Feb 2026AY 2022-23
Section 263Section 54F

submission, supported by\nrelevant documentary evidences, all of which are placed on record.\nThus, it is not a case of lack of enquiry or inadequate enquiry on the\npart of the Assessing Officer in arriving at a view, taken while\ncompleting the assessment.\n6. The moot point before

NAJMA,BUDAUN vs. PCIT, BAREILLY, BAREILLY

In the result, the appeal of the assessee is allowed

ITA 89/LKW/2022[F.Y. 2012-13]Status: DisposedITAT Lucknow13 Feb 2026

Bench: SH. SUDHANSHU SRIVASTAVA, JUDICIAL MEMBER AND SH. NIKHIL CHOUDHARY (Accountant Member)

For Appellant: Sh. Rakesh Garg, AdvFor Respondent: Sh. Neeraj Kumar, CIT DR
Section 143(3)Section 147Section 263

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 by him cannot be a basis for assumption of jurisdiction ... submitted that this was not a case of no enquiry but at best could be called a case of inadequate enquiry. He pointed to the reply submitted by the assessee before the AO in which the assessee had submitted that she had not been filing returns prior to the issue

ANIL TUTEJA,FATEHABAD vs. PR. COMMISSIONER OF INCOME TAX, ROHTAK, ROHTAK

In the result, all the above appeals filed by the respective assessee’s are dismissed

ITA 780/CHANDI/2025[2018-19]Status: DisposedITAT Chandigarh11 Feb 2026AY 2018-19

Bench: BEFORE: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

For Appellant: Shri Parikshit Aggarwal, C.A (Virtual)For Respondent: Shri Manav Bansal, CIT, DR

assessment order u/s 143(3) and in directing the AO to make assessment afresh on the ground that the assessment order was passed under inadequate enquiry. 1.3 The Worthy Pr. CIT, has erred in holding that the assessment order requires to be revised u/s 263 since the interest received ... examining this basic legal distinction, resulting in incorrect allowance of exemption. 29. The learned DR submits that this is not a case of inadequate enquiry but a case of complete lack of enquiry. The assessment order is silent on: the head under which interest income was assessed,  the applicability

KARAN PRATAP SINGH,SIRSA, HARYANA vs. ITO, WARD-1, SIRSA, HARYANA

In the result, all the above appeals filed by the respective assessee’s are dismissed

ITA 761/CHANDI/2025[2018-19]Status: DisposedITAT Chandigarh11 Feb 2026AY 2018-19

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

For Appellant: Shri Parikshit Aggarwal, C.A (Virtual)For Respondent: Shri Manav Bansal, CIT, DR

assessment order u/s 143(3) and in directing the AO to make assessment afresh on the ground that the assessment order was passed under inadequate enquiry. 1.3 The Worthy Pr. CIT, has erred in holding that the assessment order requires to be revised u/s 263 since the interest received ... examining this basic legal distinction, resulting in incorrect allowance of exemption. 29. The learned DR submits that this is not a case of inadequate enquiry but a case of complete lack of enquiry. The assessment order is silent on: the head under which interest income was assessed,  the applicability

MUNISH KUMAR LEGAL HEIR LATE SH GURDEEP SINGH,VILL MANAKPUR, YAMUNANAGAR vs. ITO, WARD 5, YAMUNANAGAR

In the result, all the above appeals filed by the respective assessee’s are dismissed

ITA 754/CHANDI/2025[2018-19]Status: DisposedITAT Chandigarh11 Feb 2026AY 2018-19

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

For Appellant: Shri Parikshit Aggarwal, C.A (Virtual)For Respondent: Shri Manav Bansal, CIT, DR

assessment order u/s 143(3) and in directing the AO to make assessment afresh on the ground that the assessment order was passed under inadequate enquiry. 1.3 The Worthy Pr. CIT, has erred in holding that the assessment order requires to be revised u/s 263 since the interest received ... examining this basic legal distinction, resulting in incorrect allowance of exemption. 29. The learned DR submits that this is not a case of inadequate enquiry but a case of complete lack of enquiry. The assessment order is silent on: the head under which interest income was assessed,  the applicability

MADHU GREWAL,CHANDIGARH vs. PRINCIPAL COMMISSIONER OF INCOME TAX, CHANDIGARH-1, CHANDIGARH

In the result, all the above appeals filed by the respective assessee’s are dismissed

ITA 603/CHANDI/2024[2019-20]Status: DisposedITAT Chandigarh11 Feb 2026AY 2019-20

Bench: the Tribunal as pointed out by the Registry. Considering that the issue involved is purely legal in nature, and respectfully following the ratio laid down by the Hon'ble Supreme Court in Collector, Land Acquisition v. Mst. Katiji & Others [(1987) 167 ITR 471 (SC)], which emphasizes that substantial justice should prevail over technical considerations, we condone the delay in filing these appeals.3. We shall take appeal of the assessee in ITA No. 167/Chd/2023 for A.Y 2018-19 as a lead case f

For Appellant: Shri Parikshit Aggarwal, C.A (Virtual)For Respondent: Shri Manav Bansal, CIT, DR

assessment order u/s 143(3) and in directing the AO to make assessment afresh on the ground that the assessment order was passed under inadequate enquiry. 1.3 The Worthy Pr. CIT, has erred in holding that the assessment order requires to be revised u/s 263 since the interest received ... examining this basic legal distinction, resulting in incorrect allowance of exemption. 29. The learned DR submits that this is not a case of inadequate enquiry but a case of complete lack of enquiry. The assessment order is silent on: the head under which interest income was assessed,  the applicability

PARVEEN KUMAR,229,VILLAGE MANAKPUR-II,TEHSIL JAGADHRI,HARYANA vs. PRABHJOT KAUR,PCIT PANCHKULA, CHANDIGARH

In the result, all the above appeals filed by the respective assessee’s are dismissed

ITA 576/CHANDI/2024[2018-2019]Status: DisposedITAT Chandigarh11 Feb 2026AY 2018-2019

Bench: the Tribunal as pointed out by the Registry. Considering that the issue involved is purely legal in nature, and respectfully following the ratio laid down by the Hon'ble Supreme Court in Collector, Land Acquisition v. Mst. Katiji & Others [(1987) 167 ITR 471 (SC)], which emphasizes that substantial justice should prevail over technical considerations, we condone the delay in filing these appeals.3. We shall take appeal of the assessee in ITA No. 167/Chd/2023 for A.Y 2018-19 as a lead case f

For Appellant: Shri Parikshit Aggarwal, C.A (Virtual)For Respondent: Shri Manav Bansal, CIT, DR

assessment order u/s 143(3) and in directing the AO to make assessment afresh on the ground that the assessment order was passed under inadequate enquiry. 1.3 The Worthy Pr. CIT, has erred in holding that the assessment order requires to be revised u/s 263 since the interest received ... examining this basic legal distinction, resulting in incorrect allowance of exemption. 29. The learned DR submits that this is not a case of inadequate enquiry but a case of complete lack of enquiry. The assessment order is silent on: the head under which interest income was assessed,  the applicability

MANINDER JEET SINGH V.P.O. UDHAMGARH,JAGADHRI,HARYANA vs. PRABHJOT KAUR,PCIT, PANCHKULA

In the result, all the above appeals filed by the respective assessee’s are dismissed

ITA 575/CHANDI/2024[2018-2019]Status: DisposedITAT Chandigarh11 Feb 2026AY 2018-2019
For Appellant: Shri Parikshit Aggarwal, C.A (Virtual)For Respondent: Shri Manav Bansal, CIT, DR

assessment order u/s 143(3) and in directing the AO to make assessment afresh on the ground that the assessment order was passed under inadequate enquiry. 1.3 The Worthy Pr. CIT, has erred in holding that the assessment order requires to be revised u/s 263 since the interest received ... examining this basic legal distinction, resulting in incorrect allowance of exemption. 29. The learned DR submits that this is not a case of inadequate enquiry but a case of complete lack of enquiry. The assessment order is silent on: the head under which interest income was assessed,  the applicability

RAM NIWAS,FATEHABAD vs. INCOME TAX OFFICER, INCOME TAX OFFICE, SIRSA ROAD, INDUSTRIAL AREA, FATEHABAD

In the result, all the above appeals filed by the respective assessee’s are dismissed

ITA 498/CHANDI/2024[2018-19]Status: DisposedITAT Chandigarh11 Feb 2026AY 2018-19

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

For Appellant: Shri Parikshit Aggarwal, C.A (Virtual)For Respondent: Shri Manav Bansal, CIT, DR

assessment order u/s 143(3) and in directing the AO to make assessment afresh on the ground that the assessment order was passed under inadequate enquiry. 1.3 The Worthy Pr. CIT, has erred in holding that the assessment order requires to be revised u/s 263 since the interest received ... examining this basic legal distinction, resulting in incorrect allowance of exemption. 29. The learned DR submits that this is not a case of inadequate enquiry but a case of complete lack of enquiry. The assessment order is silent on: the head under which interest income was assessed,  the applicability

RAKESH KUMAR,JAGADHRI vs. THE PRINCIPAL COMMISSIONER OF INCOME TAX, PANCHKULA

In the result, all the above appeals filed by the respective assessee’s are dismissed

ITA 456/CHANDI/2024[2015-16 ]Status: DisposedITAT Chandigarh11 Feb 2026

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

For Appellant: Shri Parikshit Aggarwal, C.A (Virtual)For Respondent: Shri Manav Bansal, CIT, DR

assessment order u/s 143(3) and in directing the AO to make assessment afresh on the ground that the assessment order was passed under inadequate enquiry. 1.3 The Worthy Pr. CIT, has erred in holding that the assessment order requires to be revised u/s 263 since the interest received ... examining this basic legal distinction, resulting in incorrect allowance of exemption. 29. The learned DR submits that this is not a case of inadequate enquiry but a case of complete lack of enquiry. The assessment order is silent on: the head under which interest income was assessed,  the applicability

ASHOK KUMAR THAKRAL,JAGADHRI vs. PRINCIPAL COMMISSIONER OF INCOME TAX, PANCHKULA , PANCHKULA

In the result, all the above appeals filed by the respective assessee’s are dismissed

ITA 455/CHANDI/2024[2015-16]Status: DisposedITAT Chandigarh11 Feb 2026AY 2015-16

Bench: the Tribunal as pointed out by the Registry. Considering that the issue involved is purely legal in nature, and respectfully following the ratio laid down by the Hon'ble Supreme Court in Collector, Land Acquisition v. Mst. Katiji & Others [(1987) 167 ITR 471 (SC)], which emphasizes that substantial justice should prevail over technical considerations, we condone the delay in filing these appeals.3. We shall take appeal of the assessee in ITA No. 167/Chd/2023 for A.Y 2018-19 as a lead case f

For Appellant: Shri Parikshit Aggarwal, C.A (Virtual)For Respondent: Shri Manav Bansal, CIT, DR

assessment order u/s 143(3) and in directing the AO to make assessment afresh on the ground that the assessment order was passed under inadequate enquiry. 1.3 The Worthy Pr. CIT, has erred in holding that the assessment order requires to be revised u/s 263 since the interest received ... examining this basic legal distinction, resulting in incorrect allowance of exemption. 29. The learned DR submits that this is not a case of inadequate enquiry but a case of complete lack of enquiry. The assessment order is silent on: the head under which interest income was assessed,  the applicability

KARTAR SINGH, FATEHABAD vs. PR. COMMISSIONER OF INCOME TAX, ROHTAK

In the result, all the above appeals filed by the respective assessee’s are dismissed

ITA 335/CHANDI/2023[2018-19]Status: DisposedITAT Chandigarh11 Feb 2026AY 2018-19

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

For Appellant: Shri Parikshit Aggarwal, C.A (Virtual)For Respondent: Shri Manav Bansal, CIT, DR

assessment order u/s 143(3) and in directing the AO to make assessment afresh on the ground that the assessment order was passed under inadequate enquiry. 1.3 The Worthy Pr. CIT, has erred in holding that the assessment order requires to be revised u/s 263 since the interest received ... examining this basic legal distinction, resulting in incorrect allowance of exemption. 29. The learned DR submits that this is not a case of inadequate enquiry but a case of complete lack of enquiry. The assessment order is silent on: the head under which interest income was assessed,  the applicability

SH. RAM LAL,FATEHABAD vs. PR.CIT, ROHTAK

In the result, all the above appeals filed by the respective assessee’s are dismissed

ITA 332/CHANDI/2023[2018-19]Status: DisposedITAT Chandigarh11 Feb 2026AY 2018-19

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

For Appellant: Shri Parikshit Aggarwal, C.A (Virtual)For Respondent: Shri Manav Bansal, CIT, DR

assessment order u/s 143(3) and in directing the AO to make assessment afresh on the ground that the assessment order was passed under inadequate enquiry. 1.3 The Worthy Pr. CIT, has erred in holding that the assessment order requires to be revised u/s 263 since the interest received ... examining this basic legal distinction, resulting in incorrect allowance of exemption. 29. The learned DR submits that this is not a case of inadequate enquiry but a case of complete lack of enquiry. The assessment order is silent on: the head under which interest income was assessed,  the applicability

BIMLA DEVI,JAGADHRI vs. PR.CIT, ROHTAK

In the result, all the above appeals filed by the respective assessee’s are dismissed

ITA 328/CHANDI/2023[2018-19]Status: DisposedITAT Chandigarh11 Feb 2026AY 2018-19

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

For Appellant: Shri Parikshit Aggarwal, C.A (Virtual)For Respondent: Shri Manav Bansal, CIT, DR

assessment order u/s 143(3) and in directing the AO to make assessment afresh on the ground that the assessment order was passed under inadequate enquiry. 1.3 The Worthy Pr. CIT, has erred in holding that the assessment order requires to be revised u/s 263 since the interest received ... examining this basic legal distinction, resulting in incorrect allowance of exemption. 29. The learned DR submits that this is not a case of inadequate enquiry but a case of complete lack of enquiry. The assessment order is silent on: the head under which interest income was assessed,  the applicability

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