JSIW Infrastructure Pvt. Ltd. Vs. The Principal Commissioner of Income Tax-1, Ahmedabad

Parties Involved

Facts Summary

The appeal is filed by the assessee, JSIW Infrastructure Pvt. Ltd., against the appellate order dated 05.03.2025 passed by the Principal Commissioner of Income Tax, Ahmedabad, relating to the Assessment Year 2020-21. The assessee has raised several grounds of appeal, primarily challenging the order passed by the Principal Commissioner of Income Tax (PCIT) under section 263 of the Act. The PCIT had set aside the order of the Assessing Officer on the grounds that the interest on income tax of Rs.99,37,893/- had not been disallowed by the assessee in its ITR. However, the assessee argued that the order was factually incorrect based on the record.…

Legal Issues

• 1. Whether the order passed by PCIT is bad in law and required to be quashed?
• 2. Whether PCIT erred in law and on facts in initiating proceedings u/s.263 of the Act?
• 3. Whether PCIT erred in law and on facts in proceedings with revision jurisdiction?
• 4. Whether PCIT erred in law and on facts in setting aside the order by observing that proper inquiry for claim of allowability of expenses was not made?
• 5. Whether PCIT erred in observing that AO passed an order without making any enquiry?

Judgment Outcome

Decided in favour of Assessee.

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