AXIS INFOLINE P. LTD. vs PRINCIPAL COMMISSIONER OF INCOME TAX

Parties Involved

Facts Summary

This appeal arises from an order dated 26.03.2025, passed under section 263 of the Income Tax Act, 1961, by the Learned Principal Commissioner of Income Tax (PCIT), Delhi. The Assessing Officer (AO) found certain purchases made by the assessee, Axis Infoline P. Ltd., from M/s Diwakar Enterprises amounting to Rs.1,49,86,000/- to be bogus. The AO disallowed 25% of these purchases. The PCIT, however, held that 100% of the bogus purchases deserved to be disallowed and revised the AO’s order. Aggrieved by this, the assessee approached the Income Tax Appellate Tribunal (ITAT) with several grounds of appeal, primarily arguing that the PCIT’s order was erroneous, prejudicial to the revenue, and violated principles of natural justice.…

Legal Issues

• 1. Whether the order passed by the PCIT under section 263 of the Act is erroneous and prejudicial to the revenue.
• 2. Whether the PCIT violated principles of natural justice by not providing the assessee a reasonable opportunity to be heard.
• 3. Whether the revision order passed by the PCIT is illegal, without jurisdiction, and void ab-initio.

Judgment Outcome

Decided in favour of Assessee.

Precedents Relied Upon

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