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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

Naman Vidyapati Patel, Ahmedabad vs. The Pr.CIT, Central, Ahmedabad

In the result, the appeal of the assessee stands allowed

ITA 1008/AHD/2025[2021-22]Status: DisposedITAT Ahmedabad25 Sept 2025AY 2021-22

Bench: Shri Sanjay Garg & Annapurna Guptaआयकर अपील सं /Ita No.1008/Ahd/2025 िनधा"रण वष" /Assessment Year : 2021-22 Naman Vidyapati Patel The Pr.Cit (Central) बनाम/ M/S.Markettic Ahmedabad – 380 009 V/S. Mahalaxmi Compound Opp. Rustom Mills Dudheshwar Road Ahmedabad – 380 004 "थायी लेखा सं./Pan: Acopp 9233 C (अपीलाथ(/ Appellant) ()* यथ(/ Respondent) Assessee By : Shri S.N.Divatia, Ar & Shri Samir Vora, Ar Revenue By : Shri Alpesh Parmar, Cit-Dr सुनवाई की तारीख/Date Of Hearing : 30/07/2025 घोषणा की तारीख /Date Of Pronouncement: 25/09/2025 आदेश/O R D E R Per Sanjay Garg: The Present Appeal Preferred By The Assessee Is Against The Order Of Learned Principal Commissioner Of Income-Tax (Central), Ahmedabad [Hereinafter Referred To As “Ld. Pcit” For Short] Dated 27/03/2025 Passed In Exercise Of His Revision Jurisdiction Under Section 263 Of The Income-Tax Act, 1961 [Hereinafter Referred To As "The Act" For Short] For Assessment Year (Ay) 2021-22. Naman Vidyapati Patel Vs. The Pr.Cit Central Asst. Year : 2021-22

For Appellant: Shri S.N.Divatia, AR &For Respondent: Shri Alpesh Parmar, CIT-DR
Section 143(3)Section 263

Sanjay Garg, Judicial Member: The present appeal preferred by the assessee is against the order of learned Principal Commissioner of Income-Tax (Central), Ahmedabad [hereinafter referred to as “Ld. PCIT” for short] dated 27/03/2025 passed in exercise of his revision jurisdiction under Section 263 of the Income-Tax

Aryans Educational and Charitable Trust Regd, Mohali vs. Commissioner of Income Tax, Exemptions, Chandigarh

In the result, appeal is allowed

ITA 1136/CHANDI/2024[2025-26]Status: DisposedITAT Chandigarh24 Sept 2025AY 2025-26

Bench: Shri Rajpal Yadav & Shri Krinwant Sahayआयकर अपील सं./ Ita No. 1136/Chd/2024 "नधा"रण वष" / Assessment Year: 2025-26 Aryans Educational & The Cit (Exemptions), Charitable Trust, Regd.Mohali Vs Chandigarh, C/O Shri Tej Mohan Singh, Advocate, # 527, Sector 10-D, Chandigarh. "थायी लेखा सं./Pan No: Aabta7550L अपीलाथ"/Appellant ""यथ"/Respondent Assessee By : Shri Tej Mohan Singh, Advocate Revenue By : Shri Manav Bansal, Cit Dr Date Of Hearing : 07.08.2025 Date Of Pronouncement : 24.09.2025

For Appellant: Shri Tej Mohan Singh, AdvocateFor Respondent: Shri Manav Bansal, CIT DR
Section 11Section 12ASection 12A(1)(ac)Section 13(1)(c)Section 13(1)(ii)Section 13(3)

Kailashanand Mission Trust v. Asstt. CIT (ITAT, Delhi)[2004] 88 ITD 125 (Delhi)[08-10-2003] • Amala Jyothi Vidya Kendra Trust vs. Principal Commissioner of Income-tax (Central) [2023] 157 taxmann.com 235 (Bangalore - Trib.) "Section 12AB of the Income-tax Act, 1961 - Charitable or religious trust - Procedure for registration (Cancellation ... Educational Society • Welham Boys' School Society [2006] 285 ITR 74 (Uttaranchal) • 160 taxmann.com 217 (Bangalore - Trib.) Islamic Academy of Education v. Principal Commissioner of Income-tax (Central) -Violation committed by assessee trust in assessment year 2021-22 could not be basis of cancelling section 12AB registration for assessment year

Nks Holdings P.Ltd, New Delhi vs. ACIT, Central Circle-32, New Delhi

ITA 6690/DEL/2018[2011-12]Status: DisposedITAT Delhi24 Sept 2025AY 2011-12

Bench: Shri Anubhav Sharma & Shri Amitabh Shuklaassessment Year: 2011-12 Nks Holdings Pvt. Ltd., Vs Acit, 3198/15, 4Th Floor, Gali No.1, Central Circle-32, Sangatrashan, New Delhi. Paharganj, New Delhi – 110 055. Pan: Aakcs7827C (Appellant) (Respondent) Assessee By : Shri Amol Sinha, Advocate & Shri Ankit Kumar, Advocate Revenue By : Ms Rajinder Kaur, Cit-Dr Date Of Hearing : 28.07.2025 Date Of Pronouncement : 24.09.2025 Order Per Anubhav Sharma, Jm: This Appeal Is Preferred By The Assessee Against The Order Dated 10.08.2018 Of The Commissioner Of Income-Tax (Appeals)-30, New Delhi (Hereinafter Referred To As The Ld. First Appellate Authority Or ‘The Ld. Faa’ For Short) In Appeal No.317/17-18/2980 Arising Out Of The Appeal Before It Against The Order Dated 28.12.2017 Passed U/S 144/147 Of The Income Tax Act, 1961 (Hereinafter Referred As ‘The Act’) By The Acit, Central Circle-32, New Delhi (Hereinafter Referred To As The Ld. Ao).

For Appellant: Shri Amol Sinha, Advocate &For Respondent: Ms Rajinder Kaur, CIT-DR
Section 143(1)Section 143(2)Section 144Section 147Section 148Section 68

commission income only to such sort of credit entries has been upheld by Hon’ble Bombay High Court in the case of Principal Commissioner of Income-tax-14 v. Alag Securities (P.) Ltd [2020] 117 taxmann.com 292 (Bombay) and the jurisdictional Hon’ble Delhi High Court in Dy. Commissioner