Rishabh Constructions Pvt. Ltd. vs PCIT-2, Jaipur

Parties Involved

Facts Summary

The Assessee, Rishabh Constructions Pvt. Ltd., is a company engaged in civil construction and wind power generation. The company filed its return of income for the assessment year 2022-23 on 30.12.2022, declaring a total income of Rs 27,55,830. The Assessing Officer (AO) issued a notice under section 142(1) of the Income Tax Act, 1961, dated 30.06.2023, seeking clarification on the difference between the receipts as per Form 26AS and the receipts shown in the profit and loss account. The Assessee provided a project-wise break-up of its contract receipts along with a reconciliation with Form 26AS. The AO completed the assessment on 20.03.2024 at the returned income. The Principal Commissioner of Income Tax (PCIT) issued a show cause notice dated 15.01.2026, and subsequently passed an order dated 11.02.2026, setting aside the assessment order. The Assessee appealed against this order before the Income Tax Appellate Tribunal (ITAT).…

Legal Issues

• 1. Whether the order passed by the PCIT is erroneous and prejudicial to the interests of the revenue?
• 2. Whether the AO made an enquiry on the issue at all?

Judgment Outcome

Decided in favour of Assessee.

Precedents Relied Upon

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