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“Principal Commissioner of Income-tax”

Chapter I - PreliminarySection 2 - DefinitionsSection 2(34B) / Section 1171,805 judgments

The decision most relied on for Principal Commissioner of Income-tax is CIT v. Max India Ltd. (295 ITR 282), cited in 1,162 judgments on BharatTax.

Leading authorities on Principal Commissioner of Income-tax

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.

222 Taxman 15 (Gujarat)(MAG.), Principal Commissioner of Income-tax-4 v. G & G Pharma India Ltd.
384 ITR 147 · 2016 · High Court
274
citing judgments

An assessment can be reopened if there is tangible material indicating escapement of income, demonstrating a live link between the material and the reasons recorded for reopening. The Assessing Officer must apply their mind to the material facts, and the sanction under section 151 should not be based on borrowed satisfaction.

Principal Commissioner of Income-tax v. Subodh Agarwal
149 Taxmann.com 373 · 2023 · High Court
194
citing judgments

Approval of draft assessment orders under Section 153D must be granted with due application of mind, not mechanically. Approving multiple cases, such as 38 in a single day, without proper scrutiny amounts to mechanical approval, rendering the assessment invalid.

Rajmandir Estates Private Limited v. Pr. CIT
386 ITR 162 · 2016 · High Court
131
citing judgments

The Principal Commissioner can revise an assessment under Section 263 if the Assessing Officer's inquiry into share application money or cash credits under Section 68 was inadequate, constituting an order erroneous and prejudicial to the revenue. The primary onus to prove the identity, creditworthiness, and genuineness of such credits remains with the assessee.

Financial Services Pvt. Ltd. v. Dy. CIT
457 ITR 647 · 2023 · High Court
95
citing judgments

The amended Section 151 of the Income-tax Act, governing the sanction for reassessment proceedings under Sections 148 and 148A, applies to cases initiated under the new reassessment regime. The specified authority for granting such sanction becomes the Principal Chief Commissioner or Principal Director General if more than three years have elapsed from the end of the relevant assessment year.

Sanjay Sawhney v. Principal Commissioner of Income-tax
116 Taxmann.com 701 · 2020 · High Court
87
citing judgments

Rule 27 of the ITAT Rules allows a respondent to defend a favourable order of the CIT(A) by raising grounds decided against them, even without filing an appeal or cross-objection. Such issues can be raised orally and for the first time before the Tribunal.

Principal Commissioner of Income-tax v. Agson Global (P.) Ltd.
441 ITR 550 · 2022 · High Court
87
citing judgments

When an assessee maintains proper books of accounts without defects, cash deposits made into a bank account from the available cash balance recorded in the cash book cannot be treated as unexplained cash credits under Section 68 or unexplained money under Section 69A of the Act.

Principal Commissioner of Income-tax\n(Central)-2 v. Mahesh Wood Products (P.) Ltd.
394 ITR 312 · 2017 · High Court
86
citing judgments

The date of initiation of penalty proceedings for the purpose of Section 275(1)(c) is when the Assessing Officer records a satisfaction or recommends penalty, not the later date when the Joint/Additional Commissioner of Income Tax issues the penalty notice.

Judgments citing Principal Commissioner of Income-tax

Hero Fincorp Limited, New Delhi vs. ACIT, Circle 11(1), Delhi, C.R. Building

ITA 2542/DEL/2024[2017-18]Status: DisposedITAT Delhi16 Jan 2026AY 2017-18

Bench: Shri Mahavir Singh, Vice Presdient (), Shri Satbeer Singh Godara & Shri Brajesh Kumar Singhआ.अ.सं/.I.T.A No.2542/Del/2024 निर्धारणवर्ष/Assessment Year:2017-18 Hero Fincop Ltd., 34 Community Centre, Basant Lok, Vasant Vihar, New Delhi-110057 बनाम Vs. Assistant Commissioner Of Income Tax, Circle-11(1) C. R. Building, New Delhi-110002 अपीलार्थी Appellant प्रत्यर्थी/Respondent Pan:Aaach0157J Assessee By Shri Rohit Jain, Adv., Shri Deepesh Jain, Adv. & Shri Himanshu Aggarwal Adv. Revenue By Ms. Pooja Swaroop, Cit(Dr) सुनवाईकीतारीख / Date Of Hearing: 14.01.2026 उद्घोषणाकीतारीख/Pronouncement On 16.01.2026 आदेश /Order Per Brajesh Kumar Singh, Am, The Assessee Is Engaged In The Business Of ‘Hire Purchase Leasing & Finance'. This Appeal Is Filed By The Assessee Against The Order Of National Faceless Appeal Center (Nfac)/(First Appellate Authority Hereinafter Referred As “Faa”), Delhi Dated 27.03.2024 Arising Out Of Assessment Order U/S 143(3) Of The Act Dated 29.12.2019For The Assessment Year 2017-18. 2. The Assessee Has Raised Following Grounds Of Appeal: “Disallowance Of Provision For Collection Charges -Rs. 9,75,00,000/-

Section 143(3)Section 154Section 251(1)Section 56(2)(viib)

IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH “B”, DELHI BEFORE SHRI MAHAVIR SINGH, VICE PRESDIENT (THIRD MEMBER), SHRI SATBEER

Kameshwar Alloys and Steels Pvt. Ltd., Kolkata vs. ACIT, Central Circle-1, Ranchi

In the result, the appeal of the assessee is allowed

ITA 49/RAN/2024[2014-15]Status: DisposedITAT Ranchi14 Jan 2026AY 2014-15

Bench: Shri Sonjoy Sarma & Shri Ratnesh Nandan Sahayi.T.A. No.49/Ran/2024 Assessment Year: 2014-15 Kameshwar Alloys & Steels Pvt. Ltd….…............................……….……Appellant 128/3, Hazra Road, Bhawanipur, Kol-700026.. [Pan: Aadck6558K] Vs. Acit, Cc-1, Ranchi.................……….…..….........……........……...…..…..Respondent Appearances By: Shri Devesh Poddar, Adv., Appeared On Behalf Of The Appellant. Shri Md. Shadab Ahmed, Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : December 16, 2025 Date Of Pronouncing The Order : January 14, 2026 Order Per Sonjoy Sarma: This Appeal Filed By The Assessee Is Directed Against The Order Of The Cit(A)-3, Patna (Hereinafter Referred To As “Cit(A)”) Dated 05.02.2024 Passed Under Section 250 Of The Income-Tax Act, 1961 (Hereinafter Referred To As The “Act”). 2. Brief Facts Of The Case Are That The Assessee Company, Filed Its Return Of Income For The Assessment Year Under Consideration. The Case Was Originally Selected For Scrutiny On The Issue Of Share Capital & Share Premium Received During The Year. The Assessing Officer Completed The Assessment Ex Parte Under Section 144 Of The Income-Tax Act, 1961, On The Ground Of Alleged Non-Compliance & Made An Addition Of ₹2,00,00,000 Being Share Capital & Share Premium Received From Various Companies, Treating The Same As Unexplained Under Section 68 Of The Act. Subsequently, A Search & Seizure Operation Under

Section 131Section 132(1)Section 133(6)Section 133ASection 143(3)Section 144Section 153ASection 250Section 68

issued at excess premium - Whether Special leave petition filed against impugned order was to be dismissed - Held, yes [Paras 51 and 53]  Principal Commissioner of Income-tax vs. Central Plastics (P.) Ltd. [2025] 176 taxmann.com 472 (Delhi)[07-07-2025] – 8. The Assessee preferred an appeal against the aforementioned assessment

Rakesh Divedi, Delhi vs. Income Tax Officer, Ward 43(6), Delhi

In the result, appeal of the Assessee is allowed

ITA 3290/DEL/2025[2009-10]Status: DisposedITAT Delhi09 Jan 2026AY 2009-10

Bench: Shri Sudhir Kumar & Shri Manish Agarwalrakesh Divedi, Income Tax Officer, 87, Triveni Apartments, Ward-43(6), Delhi. Pitampura, New Delhi - Vs. 110034. Pan-Apcpd9179A (Appellant) (Respondent) Shri Pranshu Singhal, Ca Assessee By & Ms. Mansi Jain, Adv. Department By Ms. Ankush Kalra, Sr. Dr Date Of Hearing 30/10/2025 Date Of Pronouncement 09/01/2026 O R D E R Per Manish Agarwal, Am: This Appeal Is Filed By The Assessee Against The Order Of The Learned Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi (‘Ld. Cit(A)’ In Short) Dated 07.03.2025 In Appeal No.40/10204/2018-19 Arising Out Of The Order Passed By The Income Tax Officer, Ward-40(3) U/S 143(3) Of The Act (‘The Act’ For Short) Dated 20.12.2016 For Assessment Year 2009-10. 2. Brief Facts Of The Case Are That Assessee Is An Individual & Proprietor Of M/S Triambkay Gauri Impex. The Information Was Received By The Ao From Investigation Wing That There Were Cash Deposits In The Bank Account Of The Assesse With Icici Bank, However, Income Of The Assessee & Gross Receipt Has Not Rakesh Divedi Vs. Income Tax Officer Commensurate With The Cash So Deposited, Therefore, After Recording The Reason U/S 147, Notice U/S 148 Was Issued On 31.03.2016 After Obtaining Statutory Approval From The Pcit. Thereafter, Assessment Was Completed Vide Order Dated 20.12.2016 Wherein Total Addition Of Rs. 5,20,88,345/- Was Made U/S 68 Of The Act For Cash Deposited In The Bank Accounts By Holding The Same As Unexplained Cash Credits. 3. Against The Said Order, Assessee Has Filed An Appeal Before Ld. Cit(A) Who Vide Impugned Order Has Partly Allowed The Appeal Of The Assessee & Directed The Ao To Make Addition Of Peak Credit Of The Total Deposits In The Bank Accounts.

Section 143(2)Section 143(3)Section 147Section 148Section 151Section 68

jurisdictional Assessing Officer, and was recommended by a Range Officer on March 25, 2021, and approved by the Principal Commissioner of Income-tax on the same day all under section 151 of the Act. Therefore, the reassessment has been contemplated and initiated one year after the expiry of four years ... facts and the applicable law and then accord sanction. In the instant case, the proposed reassessment was sanctioned by the Principal Commissioner of Income-tax, with the following remarks: "Yes, I am satisfied with the reasons recorded by the Assessing Officer for issuance of notice under section

Saurashtra Cement Limited, Porbandar vs. The Principal Commissioner of Income Tax, Jamnagar

In the result, appeal filed by the assessee is allowed

ITA 307/RJT/2024[2018-19]Status: DisposedITAT Rajkot08 Jan 2026AY 2018-19

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं/.Ita No.307/Rjt/2024 िनधा"रणवष"/ Assessment Year: 2018-19 Saurashtra Cement Ltd. Principal Commissioner Of Near Railway Station, बनाम Income Tax, Jamnagar, Saurashtra Cement Factory, Jamnagar Vs. P.O. Ranavav, Adityana Road, Porbandar, Gujarat-360560 Pan : Aahfs5211J (अपीलाथ"/Assessee) : (""थ"/Respondent) िनधा"रती की ओर से/Assessee By : Shri Vimal Desai, Ld.Ar राज" की ओर से/Revenue By : Shri Sanja Punglia, Ld. Cit-Dr सुनवाई की तारीख/Date Of Hearing : 16/10/2025 घोषणा की तारीख/Date Of Pronouncement : 08/01/2026 Order

For Appellant: Shri Vimal Desai, ld.ARFor Respondent: Shri Sanja Punglia, Ld. CIT-DR
Section 143(3)Section 14ASection 263Section 36(1)(iii)

Accountant Member: By way of this appeal, the assessee has challenged the correctness of the order dated 19.03.2024 passed by the Learned Principal Commissioner of Income-tax (in short “Ld PCIT”) under section 263 of the Income-tax Act, 1961 (hereinafter referred to as 'the Act'), for the assessment year ... Income-tax Act (in short 'the Act') on 29/10/2021, determining total income of Rs.37,04,75,290/-. 3. Later on, Learned Principal Commissioner of Income-tax (in short “Ld PCIT”), has exercised his jurisdiction under section 263 of the Income-tax Act, 1961.On perusal of case records, ld.PCIT observed that