Shahi Exports Private Ltd. vs PCIT (Central)

Parties Involved

Facts Summary

The assessee, Shahi Exports Private Ltd., is a private limited company engaged in the business of manufacturing and export of readymade garments. For the assessment years 2017-18 and 2018-19, the assessment orders were passed on 22.04.2021 and 04.06.2021, respectively. These orders were subject to revision under section 263 of the Income Tax Act, 1961. The Principal Commissioner of Income-tax (Central), Delhi-1, held that the assessment orders were erroneous as prejudicial to the interests of the revenue due to the failure of the assessing officer to make disallowance under section 36(1)(va) of the Act. The assessee challenged this revisionary order, arguing that the original assessment was valid as per the existing law at the time.…

Legal Issues

• 1. Whether the assessment orders can be deemed erroneous under section 263 of the Income Tax Act for not making disallowance under section 36(1)(va).

Judgment Outcome

Decided in favour of Assessee.

Precedents Relied Upon

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