MAHESH REDDY,BANGALORE vs. PRINCIPAL COMMISSIONER OF INCOME TAX, BENGALURU-2, BENGALURU

In the result, both the appeals of the assessee are allowed

263 of the Act.\n2.10 On the facts and in the circumstances of the case and in law, the\nLearned Pr. CIT erred in revising the assessment order under section\n263 of the Act without appreciating that order of the Assessing Officer\nis not prejudicial to the interest of the revenue and hence needs to be\nquashed.\n3. Grounds relating

MAHESH REDDY ,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-2(2)(1), BANGALORE

In the result, both the appeals of the assessee are allowed

263 of the Act.\n2.10 On the facts and in the circumstances of the case and in law, the\nLearned Pr. CIT erred in revising the assessment order under section\n263 of the Act without appreciating that order of the Assessing Officer\nis not prejudicial to the interest of the revenue and hence needs to be\nquashed.\n3. Grounds relating

JANATA TRADERS,GADAG vs. PRINCIPAL COMMISSIONER OF INCOME TAX, HUBLI

In the result, the appeal filed by the assessee is allowed

Bench: Shri N.V. Vasudevan & Shri Chandra Poojariassessment Year: 2017-18

Section 263 in the following cases: (i) The order sought to be revised contains error of reasoning or of law or of fact on the face of it. Janata Traders, Gadag Page 13 of 29 (ii) The order sought to be revised proceeds on incorrect assumption of facts or incorrect application of law. In the same category fall orders passed

M/S. ETA STAR INFOPARK,BENGALURU vs. PRINCIPAL COMMISSIONER OF INCOME TAX-1, BENGALURU

Bench: Shri Chandra Poojari & Smt. Beena Pillai

disallowed a sum of Rs.51,74,991/-. 4.10 Under the provisions of section 263 of the Act, the Ld. PCIT/CIT

M/S. ETA STAR INFOPARK,BENGALURU vs. THE PRINCIPAL COMMISSIONER OF INCOME TAX, BENGALURU-1, BENGALURU

Bench: Shri Chandra Poojari & Smt. Beena Pillai

disallowed a sum of Rs.51,74,991/-. 4.10 Under the provisions of section 263 of the Act, the Ld. PCIT/CIT

BSNL EMPLOYEES CO-OPERATIVE CREDIT SOCIETY LIMITED ,HUBBALLI vs. PR. CIT, HUBBALLI , HUBBALLI

In the result the appeal filed by the assessee is allowed

disallowances, and other determinations made by the AO\non facts and Law, however, for an appeal against a revision order u/s 263 of the Act,\nthe Tribunal is essentially confine itself to examine (1) Whether the very assumption\nof 263 jurisdiction is valid (2) whether the PCIT's conclusion on “erroneous and\nprejudicial” are sustainable in law and (3) Whether

ADARSHA SOUHARDA SAHAKARI NIYAMIT SIRSI,SIRSI vs. PR. COMMISSIONER OF INCOME TAX, , HUBALLI

In the result the appeal filed by the assessee is allowed

disallowances, and other determinations\nmade by the AO on facts and Law, however, for an appeal against a\nrevision order u/s 263 of the Act, the Tribunal is essentially confine\nitself to examine (1) Whether the very assumption of 263\njurisdiction is valid (2) whether the PCIT's conclusion on\n“erroneous and prejudicial” are sustainable

R V DESHPANDE HUF,BANGALORE vs. PRINCIPAL COMMISSIONER OF INCOME TAX, BANGALORE-1, BANGALORE

In the result, the appeal by the assessee is partly allowed

Bench: Shri N.V. Vasudevan, Vice Preseident & Shri Padmavathy Sassessment Year : 2017-18

Section 263 was held invalid. Held in the following cases. i. Fine Jewellery (India) Ltd. v. ACIT [2012] 19 ITR 746 (Mum.)(Trib). ii. Roshan Lal Vegetable Products (P) Ltd. v. ITO, 51 SOT 1 (URO) (Asr.)(Trib.) iii. Antala Sanjaykumar Ravjibhai v. CIT [2012] 135 ITD 506 (Rajkot) (Trib.) 9. The learned Commissioner of Income Tax erred in arriving

SRI RAMASEVA BAHUSARA KSHARIYA CO-OP. SOCIETY LIMITED,SHIMOGA vs. PR. CIT, BENGALURU-1, BENGALURU

In the result the appeal filed by the assessee is allowed

Bench: Shri Prashant Maharishi & Shri Keshav Dubeyassessment Year : 2020-21 M/S. Sri Ramaseva Bahusara Kshariya Co-Op. Society Ltd. 01, Ramanna Setty Park Spm Road, Doddapete So Vs. Principal Cit Shimoga 577 202 Bengaluru-1 Karnataka Pan No :Aaajs0083P Appellant Respondent Appellant By : Sri V. Srinivasan, A.R. Respondent By : Sri Kiran D., D.R. Date Of Hearing : 11.12.2025 Date Of Pronouncement : 30.01.2026

disallowances, and other determinations made by the AO on facts and Law, however, for an appeal against a revision order u/s 263 of the Act, the Tribunal is essentially confine itself to examine (1) Whether the very assumption of 263 jurisdiction is valid (2) whether the PCIT’s conclusion on “erroneous and prejudicial” are sustainable in law and (3) Whether

WRITEMEN MEDIA PRIVATE LIMITED,BENGALURU vs. INCOME TAX OFFICER,WARD-7(1)(3), BENGALURU

In the result, appeal filed by the assessee is allowed for statistical purposes

Bench: Shri. Laxmi Prasad Sahu & Shri. Keshav Dubeyassessment Year : 2014-15

disallowance as per computation in the computation of income under normal provisions of the Act on the facts and circumstances of the case. 12. Grounds on calculation of tax liability under MAT provisions u/s 115JB of the Act: i. The learned authorities below are not justified in adopting the assessed income as Book profit while computing the income u/s 115JB

VANISHREE HOLABSU SHETTAR,GULEDGUDD vs. PRINCIPAL COMMISSIONER OF INCOME TAX, HUBLI

In the result, the appeal is allowed in favour of the assessee

Bench: Shri George George K. & Ms. Padmavathy Sassessment Year : 2017-18

section 263 of the Act, on the facts and circumstances of the case. 7. Grounds on Merits of the Case: a. The learned CIT was not justified in appreciating that the assessing officer has made proper enquiry on all of the aspects on which the revision is sought to be made, on the facts and circumstances of the case

BHARATH CREDIT CO-OPERATIVE SOCIETY LIMITED ,BANGALORE vs. PR. CIT, BANGALORE -1, BANGALORE

In the result the appeal filed by the assessee is allowed

Bench: Ms. Padmavathy S. & Shri Keshav Dubeyassessmentyear:2020-21

disallowances, and other determinations made by the AO on facts and Law, however, for an appeal against a revision order u/s 263 of the Act, the Tribunal is essentially confine itself to examine (1) Whether the very assumption of 263 jurisdiction is valid (2) whether the PCIT’s conclusion on “erroneous and prejudicial” are sustainable in law and (3) Whether

BHAVANA CO-OP CREDIT SOCIETY NIYAMITA ,SIRSI vs. INCOME TAX OFFICER, WARD-1, SIRSI

In the result the appeal filed by the assessee is allowed

Bench: Shri Prashant Maharishi & Shri Keshav Dubeyassessment Year : 2020-21

disallowances, and other determinations made by the AO on facts and Law, however, for an appeal against a revision order u/s 263 of the Act, the Tribunal is essentially confine itself to examine (1) Whether the very assumption of 263 jurisdiction is valid (2) whether the PCIT’s conclusion on “erroneous and prejudicial” are sustainable in law and (3) Whether

GONIKOPPAL PRIMARY RURAL AGRICULTURAL CREDIT CO-OPERATIVE SOCIETY LIMITED ,KODAGU vs. PR. COMMISSIONER OF INCOME TAX, BENGALURU-3, BENGALURU

In the result the appeal filed by the assessee is allowed

Bench: Shri Prashant Maharishi & Shri Keshav Dubeyassessment Year : 2020-21

disallowances, and other determinations made by the AO on facts and Law, however, for an appeal against a revision order u/s 263 of the Act, the Tribunal is essentially confine itself to examine (1) Whether the very assumption of 263 jurisdiction is valid (2) whether the PCIT’s conclusion on “erroneous and prejudicial” are sustainable in law and (3) Whether

ACIT, BANGALORE vs. SUTURES INDIA PRIVATE LIMITED, BANGALORE

In the result, the appeal of revenue is allowed

Bench: Shri A.K. Garodia & Shri Vijay Pal Rao

Section 263 and therefore, the disallowance made by the Assessing Officer is nothing but the decision taken by the Commissioner

MALLIKARJUN VIRUPAXAPPA YARASI,GADAG vs. PRINCIPAL COMMISSIONER OF INCOME TAX, HUBLI

In the result, the appeal of the assessee is dismissed

Bench: Shri N.V. Vasudevan & Shri Chandra Poojariassessment Year: 2017-18

section 263 of the Act, has held primarily that; The assessing officer ought to have disallowed the i. excess ESI payments

M/S UNITED BREWERIES LTD ,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-7(1)(1), BANGALORE

In the result, the appeal filed by the assessee is partly allowed

Bench: Shri George George K, Jm & Ms.Padmavathy S, Am

section 263 of the Act. On this very issue, the Tribunal held that the disallowance of year-end provision under

M/S VOLVO INDIA PVT. LTD.,,HOSAKOTE vs. CIT, BANGALORE

In the result, the appeal by the assessee is partly allowed for statistical purposes

Bench: Shri Chandra Poojari & Smt. Beena Pillaiassessment Year : 2008-09

263 was that the claim of allowance of Rs.2,36,07,661/- under the provisions of sec. 40(a)(ia) was not examined by the AO during the course of assessment proceedings.” 10. However, it is the claim of the assesee that the assessee has not claimed the benefit of the disallowance under Section