Shri Barfani Dadaji Buildcon vs. PCIT(Central), Ahmedabad

Parties Involved

Facts Summary

This appeal has been filed by the Assessee against the order dated 26.03.2026 passed by the Income Tax Department, PCIT (Central), Ahmedabad, under Section 263 of the Income-tax Act, 1961 for Assessment Year 2022-23. The Assessee has raised grounds of appeal challenging the order passed by the Principal Commissioner of Income Tax (Central), Ahmedabad, which set aside the assessment order dated 23.03.2024 passed by the Assessing Officer under section 143(3) of the Income Tax Act, 1961. The Assessee argues that the order of the Principal Commissioner was erroneous as it failed to consider the jurisdictional limitations and the statutory provisions related to penalty imposition.…

Legal Issues

• 1. Whether the failure of the Assessing Officer to initiate penalty proceedings u/s 271D of the Act makes the order liable for revision u/s 263 of the Act.

Judgment Outcome

Decided in favour of Assessee.

Precedents Relied Upon

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