ITA No. 871/JPR/2026

Parties Involved

Facts Summary

The case involves Lichamanpura Gram Sewa Sahkari Samiti Ltd, a credit cooperative society, which filed a return of income under Section 148 of the Income Tax Act after the due date specified under Section 139(1). The society claimed a deduction under Section 80P of the Act, which was allowed by the Assessing Officer (AO). The Principal Commissioner of Income Tax (PCIT) found the assessment order erroneous and prejudicial to the revenue, as the AO had allowed the deduction without verifying its eligibility under Section 80AC of the Act. The society appealed against the PCIT's order, arguing that the PCIT had incorrectly assumed jurisdiction and that the order was not erroneous. The Tribunal upheld the PCIT's order, finding that the AO had failed to conduct the necessary inquiry into the eligibility of the deduction, making the order erroneous and prejudicial to the revenue.…

Legal Issues

• 1. Whether the PCIT correctly assumed jurisdiction under Section 263 of the Income Tax Act.
• 2. Whether the order passed by the AO was erroneous and prejudicial to the revenue.

Judgment Outcome

Decided in favour of Revenue.

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