← 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

Megnanapuram Paccs, Tiruchendur vs. PCIT, Madurai

ITA 895/CHNY/2025[2018-19]Status: DisposedITAT Chennai19 Sept 2025AY 2018-19

Bench: Shri Manu Kumar Giri & Shri S.R.Raghunathaआयकर अपील सं./Ita No.:895/Chny/2025 निर्धारण वर्ष / Assessment Year: 2018-19 Megnanapuram Primary Agricultural Co-Operative Credit Society 4/40, Megnanapuram Tiruchendur Road, Tiruchendur Thoothukudi – 628 210. [Pan: Aabam-9847-M] (अपीलार्थी/Appellant) Pcit Vs. Madurai - I (प्रत्यर्थी/Respondent) अपीलार्थी की ओर से/Appellant By : Shri. N. Arjun Raj, Advocate प्रत्यर्थी की ओर से/Respondent By : Shri. Shiva Srinivas, Cit सुनवाई की तारीख/Date Of Hearing : 24.06.2025 घोषणा की तारीख/Date Of Pronouncement : 19.09.2025 आदेश /Order Per S. R. Raghunatha, Am : This Appeal By The Assessee Is Filed Against The Order Of The Commissioner Of Income Tax (Appeals), Pcit, Madurai - 1, For The Assessment Year 2018-19, Vide Order Dated 17.03.2025. 2. The Grounds Raised By The Assessee Are As Follows: :-2-:

For Appellant: Shri. N. Arjun Raj, AdvocateFor Respondent: Shri. Shiva Srinivas, CIT
Section 147Section 148Section 263Section 80P

आयकर अपीलीय अधिकरण, 'बी' न्यायपीठ, चेन्नई IN THE INCOME TAX APPELLATE TRIBUNAL 'B' BENCH, CHENNAI श्री मनु कुमार गिरि, न्यायिक

Arun Duggal, Faridabad vs. DCIT, Central Circle- 1, Faridabad

In the result, appeal of the assessee is partly allowed

ITA 3075/DEL/2018[2009-10]Status: DisposedITAT Delhi19 Sept 2025AY 2009-10

Bench: Shri Sudhir Kumar & Shri Manish Agarwal[Assessment Year : 2009-10] Arun Duggal, Vs Dcit, 3E-42, Nit, Faridabad, Central Circle-1, Haryana-121001. Faridabad. Pan-Agupd5708Q Appellant Respondent Appellant By Dr. Kapil Goel, Adv. Respondent By Shri Pravin Rawal, Cit Dr Date Of Hearing 26.06.2025 Date Of Pronouncement 19.09.2025 Order Per Manish Agarwal, Am : The Present Appeal Is Filed By Assessee Against The Order Dated 26.02.2018 Passed By Ld. Commissioner Of Income Tax (A)-3, Gurgaon [“Ld.Cit(A)”] In Appeal No.617/Cit(A)-3/Ggn/2016-17 U/S 250 Of The Income Tax Act, 1961 [“The Act”] Arising Out Of Assessment Order Dated 23.12.2016 Passed U/S 147 R.W.S. 143(3) Of The Act Pertaining To Assessment Year 2009-10. 2. Brief Facts Of The Case Are That The Appeal Of The Assessee Was Heard By The Co-Ordinate “E” Bench Of The Tribunal & Was Decided In Terms Of Order Dated 01.04.2022 Wherein Co-Ordinate Bench Has Dismissed The Appeal Of The Assessee. Thereafter, Assessee Filed Miscellaneous Application (M.A.) Bearing No.100/Del/2022 U/S 254(2) Of The Act. The Co-Ordinate Bench Vide Its Order Dated 09.04.2025 Has Decided The M.A. Filed By Assessee Wherein Order Of Co-Ordinate Bench Dated 04.01.2022 Is Recalled For The Limited Purposes Of Adjudication Of Three Grounds Of Appeal Taken In The Original Form 36. These Grounds Of Appeal Are Bearing Nos.1.2, 1.8 & 5. The Relevant Observations Of The Co-Ordinate Bench In Para 16 Of The Order Of Ma Are As Under:-

Section 147Section 151Section 250Section 254(2)Section 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

Deputy Commissioner of Income Tax, Central Circle-4(3), Kolkata vs. Raja Shelters Private Limited, Kolkata

In the result, both the captioned appeals of the revenue are dismissed

ITA 1173/KOL/2025[2009-10]Status: DisposedITAT Kolkata18 Sept 2025AY 2009-10

Bench: Shri Rajesh Kumar & Shri Pradip Kumar Choubeyita Nos.1173 & 1175/Kol/2025 Assessment Years: 2009-10 & 2013-14 Dcit, Central Circle-4(3), Kolkata.……………………….……….……….……Appellant Vs. Raja Shelters Pvt. Ltd…………………….…………………….....……...…..…..Respondent 25A, S. P. Mukherjee Road, Kol- 700025. [Pan: Aadcr5073Q] Appearances By: Shri Sanat Kr. Raha, Cit-Dr, Appeared On Behalf Of The Appellant. Shri Miraj D. Shah, Ar, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : September 11, 2025 Date Of Pronouncing The Order : September 18, 2025 Order Per Pradip Kumar Choubey: Both The Captioned Appeals Have Been Preferred By The Revenue For The Assessment Years 2009-10 & 2013-14 Against Separate Orders Dated 21.02.2025 & 25.02.2025 Of The Commissioner Of Income Tax (Appeals)-27, Kolkata [Hereinafter Referred To As ‘Cit(A)’] Passed U/S 250 Of The Income Tax Act (Hereinafter Referred To As The ‘Act’) Respectively. Since, The Issues Involved In Both The Appeals Are Common & Relate To The Same Assessee, Therefore, These Appeals Have Been Heard Together & Are Being Disposed Of By This Consolidated Order.

Section 127Section 132(1)Section 133ASection 139Section 142(1)Section 143(2)Section 153ASection 250Section 68

addition amounting to Rs.15,00,000/- relying upon the judicial pronouncement of the Hon’ble Apex Court in the case of Principal Commissioner of Income-tax, Centra-3 vs. Abhisar Buildwell (P.) Ltd (2023) 149 taxmann.com 399 (SC)", however the assessment was completed on the basis of seized documents vide ... with any of the incriminating material found during the course of search proceedings. The Hon’ble Apex court in the case of ‘Principal Commissioner of Income-tax, Central-3 vs. Abhisar Buildwell (P.) Ltd [2023] 149 taxmann.com 399 (SC)’ clearly stated that any addition made by the assessing officer without

Muniyappa Muniraju, Bengaluru vs. Pr. Commissioner of Income Tax, Bengaluru-2, Bengaluru

In the result, appeal filed by the assessee is allowed

ITA 1119/BANG/2025[2017-18]Status: DisposedITAT Bangalore11 Sept 2025AY 2017-18

Bench: Shri Laxmi Prasad Sahu & Shri Soundararajan Kassessment Year : 2017-18 Shri. Muniyappa Muniraju, Vs. Pr. Cit, No.1/3, 1St Cross, Muni Narasimhaiah Bangalore - 2. Garden, Chocolate Factory Main Road, Btm I Stage, Bangalore – 560 029, Karnataka. Pan : Anjpm 0458 N Appellant Respondent Assessee By : Shri. Narendra Sharma, Advocate Revenue By : Shri. Muthu Shankar, Cit(Dr)(Itat), Bangalore. Date Of Hearing : 04.09.2025 Date Of Pronouncement : 11.09.2025

For Appellant: Shri. Narendra Sharma, AdvocateFor Respondent: Shri. Muthu Shankar, CIT(DR)(ITAT), Bangalore
Section 139(1)Section 142(1)Section 143(2)Section 147Section 148Section 194CSection 194HSection 263Section 44A

appellant of Rs. 5,48,500/-.  Thereafter, revision proceedings under section 263 of the Act were initiated by the Hon’ble Principal Commissioner of Income-tax, Bengaluru – 1, Bengaluru by issuance of Show Cause Notice under section 263 of the Act, dated 28/12/2023, by erroneously observing that the commission income ... received of Rs. 12,00,000/-. The appellant filed the details and documents in support of his case and the Hon’ble Principal Commissioner of Income-tax, Bengaluru – 1, Bengaluru vide order of revision under section 263 of the Act, dated 12/03/2024, held that the order of re- assessment passed