ITA Nos.1137 to 1139/Chny/2024

Parties Involved

Facts Summary

The assessee company, M/s. Anitha Texcot (India) Pvt. Ltd., had undergone a search and seizure operation under section 132 of the Income Tax Act, 1961 on 17.03.2021. Following this, the case was centralized with the DCIT, Central Circle-1, Coimbatore, who issued a notice under section 153A of the Act to the assessee company for the assessment years 2015-16 to 2020-21 on 30.10.2021. The assessee filed returns of income for the assessment years 2018-19, 2019-20, and 2020-21 declaring total taxable incomes of ₹16,07,55,090/-, ₹25,97,75,910/-, and ₹31,58,43,390/- respectively. The Assessing Officer made additions to the income for these years, which were challenged by the Principal Commissioner of Income Tax (Central), Chennai-2, who invoked his revisional jurisdiction under section 263 of the Act. The assessee appealed against this order to the Income Tax Appellate Tribunal.…

Legal Issues

• 1. Whether the Principal Commissioner of Income Tax (Central) had the jurisdiction to invoke revisional jurisdiction under section 263 of the Act?
• 2. Whether the omission to initiate penalty proceedings under section 270A of the Act was erroneous?

Judgment Outcome

Decided in favour of Assessee.

Precedents Relied Upon

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