← All Phrases

“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

ITO, Ward-4(2)(3), Ahmedabad vs. Maheshwari Sales Corporation, Ahmedabad

In the result, the appeal filed by the Revenue stands dismissed

ITA 1306/AHD/2025[2018-19]Status: DisposedITAT Ahmedabad30 Oct 2025AY 2018-19

Bench: Annapurna Gupta & Shri Siddhartha Nautiyalआयकर अपील सं /Ita No.1306/Ahd/2025 िनधा"रण वष" /Assessment Year : 2018-19 The Ito Maheshwari Sales Corporation बनाम/ Ward-4(2)(3) C-111, Ganesh Meridin V/S. Ahmedabad Nr.Sola Bridge, Sola Ahmedabad-380 058 "थायी लेखा सं./Pan: Aalfm 4917 H (अपीलाथ"/ Appellant) ("" यथ"/ Respondent) Assessee By : Shri Mehul K. Patel, Ar Revenue By : Smt. Mamta Singh, Sr.Dr सुनवाई की तारीख/Date Of Hearing : 01/09/2025 घोषणा की तारीख /Date Of Pronouncement: 30/10/2025 आदेश/O R D E R Per Siddhartha Nautiyal, Jm: This Appeal By The Revenue Is Directed Against The Order Of The Ld.Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi [Hereinafter Referred To As “Cit(A)”], Dated 11/04/2025, Passed U/S.250 Of The Income Tax Act, 1961 (Hereinafter Referred To As ‘The Act’) For The Assessment Year (Ay) 2018-2019. 2. The Revenue Has Raised The Following Grounds Of Appeal: Ito Vs. Maheshwari Sales Corporation Asst. Year : 2018-19

For Appellant: Shri Mehul K. Patel, ARFor Respondent: Smt. Mamta Singh, Sr.DR
Section 132Section 147Section 250Section 68

independent enquiry and affording opportunity to Assessee to convert statements made by seller. The Bombay High Court in the case of Principal Commissioner of Income-tax v. Vaman International (P.) Ltd. [2020] 422 ITR 520 (Bom) deleted the addition made by the Assessing Officer in the absence of any inquiry

Gmm Pfaulder Ltd., Ahmedabad vs. The Pr.CIT, Ahmedabad-1, Ahmedabad

In the result, the appeal of the assessee is allowed

ITA 839/AHD/2025[2020-21]Status: DisposedITAT Ahmedabad28 Oct 2025AY 2020-21

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinhaआयकर अपील सं /Ita No.839/Ahd/2025 िनधा"रण वष" /Assessment Year : 2020-21 Gmm Pfaulder Ltd. The Pr.Cit बनाम/ 3Rd Floor, B-Jadav Chambers Ahmedabad-1 V/S. Navrangpura H.O. Ahmedabad – 380 015 Ashram Road Ahmedabad – 380 009 "थायी लेखा सं./Pan: Aabcg 0563 A (अपीलाथ"/ Appellant) ("" यथ"/ Respondent) Assessee By : Shri S.N. Soparkar, Sr. Advocate Revenue By : Shri Sher Singh, Cit-Dr सुनवाई की तारीख/Date Of Hearing : 09/09/2025 घोषणा की तारीख /Date Of Pronouncement: 28 /10/2025 आदेश/O R D E R Per Siddhartha Nautiyal, Jm: This Appeal Filed By The Assessee Is Directed Against The Order Of Learned Principal Commissioner Of Income-Tax, Ahmedabad-1 [Hereinafter Referred To As “Ld. Pr. Cit” For Short] Dated 07/03/2025 Passed In Exercise Of His Revisionary Jurisdiction Under Section 263 Of The Income-Tax Act, 1961 [Hereinafter Referred To As "The Act" For Short] For Assessment Year (Ay) 2020- 21. 2. The Assessee Has Raised The Following Grounds Of Appeal: Gmm Pfaulder Ltd. Vs. Pcit Asst. Year : 2020-21 2

For Appellant: Shri S.N. Soparkar, Sr. AdvocateFor Respondent: Shri Sher Singh, CIT-DR
Section 135Section 143(3)Section 144BSection 263Section 32Section 80G

SIDDHARTHA NAUTIYAL, JM: This appeal filed by the assessee is directed against the order of Learned Principal Commissioner of Income-Tax, Ahmedabad-1 [hereinafter referred to as “Ld. Pr. CIT” for short] dated 07/03/2025 passed in exercise of his revisionary jurisdiction under Section 263 of the Income-Tax ... mind on this issue. The learned counsel further relied on the recent judgment of the Hon’ble Gujarat High Court in Principal Commissioner of Income-tax-1 v. Aculife Healthcare (P.) Ltd. [2023] 155 taxmann.com 283 (Guj.) / [2025] 477 ITR 392 (Guj.) (dated 28.08.2023), wherein the Court held that where

ACIT, Circle, Gandhidham vs. Kutch District Co-Operative Milk Producers Union Limited, Anjar

In the result, appeal find by the revenue is dismissed

ITA 212/RJT/2025[2017-18]Status: DisposedITAT Rajkot27 Oct 2025AY 2017-18

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं/.Ita No.212/Rjt/2025 "नधा"रणवष"/ Assessment Year: 2017-18 The Acit, Circle, Kutch District Co-Operative बनाम Gandhidham Milk Producers Union Ltd. Vs. C.O. Apmc Premises, Versamedi Naka, Near Railway Crossing Anjar, Gujarat-37010 Pan : Aaaak9845N (अपीलाथ"/Appellant) (""यथ"/Respondent) : "नधा"रती क" ओर से/Assessee By : Shri Akshay Modi, Ld.Ar राज"व क" ओर से/Revenue By : Shri Sanjay Punglia, Ld. Cit-Dr

For Appellant: Shri Akshay Modi, ld.ARFor Respondent: Shri Sanjay Punglia, Ld. CIT-DR
Section 143(3)Section 144BSection 250Section 263Section 80PSection 80P(2)(d)

Milk Producers Union Ltd. ITA No.212 /RJT/2025 (AY : 2017-18) 6 11. The Supreme Court of India in the case of Principal Commissioner of Income-tax, Surat-2 v. Shreeji Prints (P.) Ltd. [2[2021] 130 taxmann.com 294/282 Taxman 464 (SC) dismissed SLP filed by the assessee against order passed ... Purba Agro Food Pvt. Ltd amounting to Rs. 2.49 Crore and the Assessing Officer allowed these unsecured loans. The Principal Commissioner of Income-tax invoked. Section 263 of the Act, 1961 for revising the assessed income of the respondent assessee. It was noticed by the PCIT that the unsecured loans