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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

Income Tax Officer- 6(2), Lucknow vs. M/S. Status Vyapaar Pvt. Ltd., Lucknow

ITA 403/LKW/2020[2012-13]Status: HeardITAT Lucknow13 Aug 2025AY 2012-13

Bench: Shri Kul Bharat & Shri Anadee Nath Misshraआयकर अपील सं/ Ita No.403/Lkw/2020 निर्धारण वर्ष / Assessment Year: 2012-13 Income Tax Officer-6(2) 27/2, Raja Ram Mohan Rai Marg, P. K. Complex, 3Rd Floor, Lucknow-226001. V. M/S. Status Vyapaar Pvt Ltd 24, Eldico Greens, Gomti Nagar, Lucknow-226010. Pan:Arvpm1497R अपीलार्थी/(Appellant) प्रत्यर्थी/(Respondent) अपीलार्थी कि और से/Appellant By: Shri Raghunath Mishra, Adv प्रत्यर्थी कि और से /Respondent By: Shri R. K. Agarwal, Cit(Dr) Order Per Anadee Nath Misshra, Am.: This Appeal, By The Revenue, Is Directed Against The Order Of The Learned Commissioner Of Income-Tax (Appeals)-2, Lucknow Dated 24.09.2020, Pertaining To The Assessment Year 2012-13. The Revenue Has Raised The Following Grounds Of Appeal: - “1. Whether On The Facts Of Circumstances Of The Case & In Law. Ld. Cit(A)-2, Lucknow Erred In Restricting The Addition Of Rs.6,34,00,000/- Made By The Ao On Account Of Unexplained Credit U/S 68 Of The Act To Commission Income Calculated At 1% Without Appreciating That The Assessee Had Failed To Furnish Satisfactory Explanation With Regard To Identify Of The Parties, Source & Genuineness Of The Transaction 2. The Appellant Craves Leave To Add Or Amend Any One Or More Of The Grounds Of Appeal As & When Need To Doing So Arises With The Prior Permission Of The Court.” 2. In This Case, Assessment Order Dated 29.12.2019 Was Passed By The Assessing Officer Whereby The Assessee'S Total Income Was Assessed At Rs.6,34,42,150/-. Thereafter, During The Assessment Proceedings, The Assessing Officer Noted That There Were Total Credit Entries Of Rs.9.84 Crores & Matching Debit

For Appellant: Shri Raghunath Mishra, AdvFor Respondent: Shri R. K. Agarwal, CIT(DR)
Section 150Section 68

fees charge toward providing such entries which may vary between 0.2% to 1% of amount transactions. Reliance is placed on following: Principal Commissioner of Income-tax-14 v. Alag Securities (P.) Ltd. (2020 117 taxmann.com 292 (Bombay) Section 68 of the Income-tax Act, 1961 Cash credits (Accommodation entries) Assessment

Shiva Kesava Mahasannidhanam Kokapeta, Ranga Reddy vs. CIT (Exemption), Hyderabad

In the result, both the appeals filed by the assessee are allowed for statistical purposes

ITA 930/HYD/2025[-]Status: DisposedITAT Hyderabad13 Aug 2025

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Madhusudan Sawdiaआ.अपी.सं /Ita Nos.929 & 930/Hyd/2025 (िनधा"रण वष"/Assessment Year: Na) Shiva Kesava Vs. Cit (Exemptions) Mahasannidhanan, Hyderabad Kokapeta, R.R. Distt. Pan:Aamts0303E (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri Pawan Kumar Chakrapani, Ca राज" व "ारा/Revenue By:: Shri Ravindra Kumar Naik, Cit(Dr) सुनवाई की तारीख/Date Of Hearing: 12/08/2025 घोषणा की तारीख/Pronouncement: 13/08/2025 आदेश/Order Per Vijay Pal Raothese 2 Appeals By The Assessee Are Directed Against The Separate Orders Of The Learned Cit (Exemptions), Hyderabad Both Dated, 20/11/2024 Whereby The Application Of The Assessee For Registration U/S 12Ab & Approval U/S 80G(5) Of The I.T. Act Were Dismissed.

For Appellant: Shri Pawan Kumar Chakrapani, CAFor Respondent: : Shri Ravindra Kumar Naik, CIT(DR)
Section 12ASection 80GSection 80G(5)

following grounds of appeals: “1. The order of rejection for approval under section 12AB of the Act, passed by the learned Principal Commissioner of Income-tax [Exemption], Hyderabad, dated 20/11/2024, in so far as it is against the Appellant is opposed to law, equity, weight of evidence, probabilities ... facts and circumstances in the Appellant’s case. 2. Whether the learned Principal Commissioner of Income-tax (Exemptions), Hyderabad, is justified in mechanically rejecting the application filed by the Appellant for registration of the Appellant Trust under section 12AB of the Act, under the facts and circumstances of the case

Shiva Kesava Mahasannidhanam Kokapeta, Ranga Reddy vs. CIT(Exemption), Hyderabad

In the result, both the appeals filed by the assessee are allowed for statistical purposes

ITA 929/HYD/2025[-]Status: DisposedITAT Hyderabad13 Aug 2025

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Madhusudan Sawdiaआ.अपी.सं /Ita Nos.929 & 930/Hyd/2025 (िनधा"रण वष"/Assessment Year: Na) Shiva Kesava Vs. Cit (Exemptions) Mahasannidhanan, Hyderabad Kokapeta, R.R. Distt. Pan:Aamts0303E (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri Pawan Kumar Chakrapani, Ca राज" व "ारा/Revenue By:: Shri Ravindra Kumar Naik, Cit(Dr) सुनवाई की तारीख/Date Of Hearing: 12/08/2025 घोषणा की तारीख/Pronouncement: 13/08/2025 आदेश/Order Per Vijay Pal Raothese 2 Appeals By The Assessee Are Directed Against The Separate Orders Of The Learned Cit (Exemptions), Hyderabad Both Dated, 20/11/2024 Whereby The Application Of The Assessee For Registration U/S 12Ab & Approval U/S 80G(5) Of The I.T. Act Were Dismissed.

For Appellant: Shri Pawan Kumar Chakrapani, CAFor Respondent: : Shri Ravindra Kumar Naik, CIT(DR)
Section 12ASection 80GSection 80G(5)

following grounds of appeals: “1. The order of rejection for approval under section 12AB of the Act, passed by the learned Principal Commissioner of Income-tax [Exemption], Hyderabad, dated 20/11/2024, in so far as it is against the Appellant is opposed to law, equity, weight of evidence, probabilities ... facts and circumstances in the Appellant’s case. 2. Whether the learned Principal Commissioner of Income-tax (Exemptions), Hyderabad, is justified in mechanically rejecting the application filed by the Appellant for registration of the Appellant Trust under section 12AB of the Act, under the facts and circumstances of the case