GYAN INFRABUILD PVT. LTD,VARANASI vs. ACIT CENTRAL CIRCLE-03, PATNA
In the result, all the appeals of the assessee for Assessment Year
ITA 177/PAT/2023[2017-18]Status: DisposedITAT Patna13 May 2024AY 2017-18
Bench: Shri Sonjoy Sarma, Hon’Blei.T.A. No. 175 To 178/Pat/2023 Assessment Year: 2015-16 To 2018-19 Gyan Infrabuild Private Limited Principal Commissioner Of Awlespur, Kandwa Vs Income-Tax (Central), Patna Varanasi - 221006 [Pan: Aaecg0509Mc] अपीलाथ"/ (Appellant) "" यथ"/ (Respondent) Assessee By : Shri S.C. Aggrawal, Sr. Adv. & Shri Manish Rastogi, Adv. Revenue By : Md. A.H. Chowdhary, Cit, D/R सुनवाई क" तारीख/Date Of Hearing : 05/03/2024 घोषणा क" तारीख /Date Of Pronouncement: 13/05/2024 आदेश/O R D E R Per, Dr. Manish Borad: The Present Appeals Are Directed At The Instance Of The Assessee Against The Separate & Identical Orders Of The Learned Principal Commissioner Of Income Tax (Central), Patna (Hereinafter The “Ld. Pr. Cit”) Even Dt. 26/03/2022, Passed U/S 263 Of The Income Tax Act, 1961 (“The Act”) For The Assessment Year 2015-16 To 2018-19. 2. The Registry Has Pointed Out That There Is A Delay Of 14 Days In Filing Of These Appeals. There Is A Petition For Condonation Of Delay Stating Therein, The Reasons For The Delay. Relevant Content Of The Petition Dt. 08/06/2023 Is Extracted For Ready Reference:- “…….. 1. That We Had Received An Order U/S 263 Passed By Id Principal Commissioner Of Income-Tax, Central Circle, Patna On 26.03.2022. 2
For Appellant: Shri S.C. Aggrawal, Sr. Adv. & Shri Manish Rastogi, AdvFor Respondent: Md. A.H. Chowdhary, CIT, D/R
Section 132Section 133ASection 153ASection 263
revision can be exercised only where no enquiry, as required under the law, is done. It is not open to enquire in case of inadequate inquiry.
16. The ITAT in the case of Mrs. Khatiza S. Oomerbhoy vs. ITO, Mumbai,
101 TTJ 1095, analyzed in detail various authoritative pronouncements including the decision of Hon'ble Supreme Court in the case