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. 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

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

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

Bench: Shri Chandra Poojari & Shri Soundararajan K.

263 of the Act without appreciating that order of the Assessing Officer is not prejudicial to the interest of the revenue and hence needs to be quashed. 3. Grounds relating to deduction under section 54 of the Act 3.1 The learned Pr.CIT erred in stating that the deduction amounting to Rs.4,80,33,694/- was incorrectly claimed under section

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

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

Bench: Shri Chandra Poojari & Shri Soundararajan K.

263 of the Act without appreciating that order of the Assessing Officer is not prejudicial to the interest of the revenue and hence needs to be quashed. 3. Grounds relating to deduction under section 54 of the Act 3.1 The learned Pr.CIT erred in stating that the deduction amounting to Rs.4,80,33,694/- was incorrectly claimed under section

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

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

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

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

CISCO SYSTEMS (INDIA) PRIVATE LIMITED,BANGALORE vs. THE PRINCIPAL COMMISSIONER OF INCOME TAX - 2, KORAMANGALA, BANGALORE

In the result, the appeal of the assessee is hereby dismissed

Bench: Shri Waseem Ahmed & Shri Soundararajan Kassessment Year: 2021-22

263 of the Act, for the assessment year 2021–22, has been issued by ld. PCIT, Bengaluru–2, vide DIN and Notice No. ITBA/REV/F/2024-25/104737420731 dated 26.02.2025. The notice proposes to revise the assessment order passed under section 143(3) read with section 144B of the Act on 29.12.2022 on the ground that the said order is erroneous and prejudicial

M/S. EMBASSY PROPERTY DEVELOPMENTS PRIVATE LIMITED,BANGALORE vs. THE PRINCIPAL COMMISSIONER OF INCOME-TAX, (CENTRAL), BANGALORE

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

263 of the Act dated 24.02.2022 proposing to revise the order passed under Section 143(3) of the Act for the reasons stated below - (i) In relation to the loans given by VTM Infrastructure Management Private Limited (WIMPL') to the Assessee, all the requisite conditions provided under section 2(22)(e) of the Act have been satisfied. However, the Assessing