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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

Shri Multanchand Bora Trust, Pune vs. ACIT, Exemption, Circle- Aurangabad, Aurangabad

In the result, the Appeal of the assessee is partly allowed

ITA 1312/PUN/2025[2020-21]Status: DisposedITAT Pune09 Dec 2025AY 2020-21

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपऩल सं. / Ita No.1312/Pun/2025 निर्धारण वषा / Assessment Year: 2020-21 Shri Multanchand Bora Trust, V The Assistant/Deputy 132B/2A, Ganeshkhind Road, S. Commissioner Of Income Pune – 411007. Tax, Exemption Circle, Aurangabad. Pan: Aafts3329F Appellant/ Assessee Respondent / Revenue Assessee By Shri Shrenik Gandhi Revenue By Shri Amit Bobde –Cit(Dr) Date Of Hearing 11/09/2025 Date Of Pronouncement 09/12/2025 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Appeal Is Filed By The Assessee Against The Order Of Ld.Commissioner Of Income Tax(Exemption), Pune At Nashik Passed Under Section 263 Of The Income Tax Act, 1961 For A.Y.2020-21, Dated 30.03.2025 Emanating From Assessment Order U/S.143(3) Of The I.T.Act, Dated 20.09.2022. The Assessee Has Raised Following Grounds Of Appeal : “1. Ground No. 1: The Learned Cit (Exemption) Seriously Erred On The Facts & Law, In Exercising The Revisionary Powers Under Section

Section 143(3)Section 263Section 80G

Commissioner of Income-tax Vs. Future Corporate Resources Ltd. [2022] 284 Taxman 122 (Bombay) iv. Bajaj Housing Finance Ltd. Vs. Principal Commissioner of Income-tax [2024] 161 taxmann.com 213(Pune Tribunal) Submission of ld.DR : 5. Ld.Departmental Representative(ld.DR) for the Revenue relied on the order of ld.CIT(Exemption