Amar Kishore Singh vs. ITO Ward-3(1), Purnea, Bihar

Parties Involved

Facts Summary

The present Appeal is filed by the Assessee against the order of the Principal Commissioner of Income Tax-I, Patna (‘Ld. PCIT’ for short) dated 22.04.2026, passed u/s 154/264 of the Income Tax Act, 1961 (“the Act”, for short) for the Assessment Year 2017-18. An Assessment Order came to be passed u/s 147 r.w.s. 144B of the Act on 21.03.2022 making an addition of Rs.47,11,000/- u/s 69 of the Act and Rs.2,55,434/- as income from other sources (interest). Instead of challenging the Assessment Order before the Ld. CIT(A), Assessee preferred an application u/s 264 of the Act before the Ld. PCIT, which came to be dismissed due to delay in latches on 26.09.2025 by the Ld. Principal Commissioner of Income Tax. Further, Assessee has also filed an application u/s 154 of the Act before the Ld. PCIT to ‘rectify the error in the order of the Ld. PCIT dated 26.09.2026. The Ld. PCIT vide Order dated 22.04.2026, dismissed the said Application of the Assessee. As against the order of the Ld. PCIT dated 22.04.2026 passed u/s 154/264 of the Act, Assessee preferred the present Appeal.…

Legal Issues

• 1. Whether the Assessee is entitled to relief against the order of the Principal Commissioner of Income Tax?
• 2. Whether the Assessee can challenge the Assessment order dated 21.03.2022 before the CIT(A)?

Judgment Outcome

Decided in favour of Assessee.

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