SMT. VANDANA SARAOGI,KATNI vs. PCIT(CENTRAL) BHOPAL AT JABA, JABALPUR
In the result, the appeal of the assessee is allowed
ITA 86/JAB/2024[2016-17]Status: DisposedITAT Jabalpur12 Dec 2025AY 2016-17
Bench: Sh. Kul Bharat & Sh. Nikhil Choudharya.Y.2016-17 Smt Vandana Saraogi Vs. Principal Commissioner Prop. Mahalaxmi Industries, Ghantaghar, Of Income Tax (Central) Hanumanganj Ward, Katni-483222. Bhopal At Jabalpur Director General Of Income Tax, Aayakar Bhawan, 48, Arera Hills, Bhopal-462011. Pan: Asips2301L (Appellant) (Respondent) Assessee By: Sh. Dhiraj Ghai, C.A. Revenue By: Sh. Shravan Kumar Meena, Cit- Dr Date Of Hearing: 18.09.2025 Date Of Pronouncement: 12.12.2025 O R D E R Per Nikhil Choudhary, A.M. This Is An Appeal Filed By The Assessee Against The Order Of The Ld. Pcit(Central), Bhopal At Jabalpur U/S 263 Of The Income Tax Act, 1961 (“Act”, For Short) Setting Aside The Assessment Order Passed By The Assessing Officer (Ao) U/S 153A Read With Section 143(3) Of The Act Dated 22.04.2021. The Grounds Of Appeal Are As Under:-
For Appellant: Sh. Dhiraj Ghai, C.AFor Respondent: Sh. Shravan Kumar Meena, CIT- DR
Section 143(3)Section 153ASection 263Section 263(1)
block period.
6. On the facts and circumstances of the case, the learned Pr.CIT has erred both on facts and in law in ignoring the fact that the proceeding under Section 263
cannot be used for substituting opinion of the A.O. by that of the PCIT.
7 On the facts and circumstances of the case, the order passed
