Shri Mandala Subramanyam vs. Income Tax Officer

Parties Involved

Facts Summary

The assessee, Shri Mandala Subramanyam, filed his income return for the Assessment Year 2017-18 on 22.08.2017. His case was selected for limited scrutiny, and a notice under section 143(2) of the Income-tax Act, 1961 was issued. The Assessing Officer completed the assessment under section 143(3) of the Act, accepting the returned income. However, the Assessing Officer noticed that the assessee had sold three immovable properties for an aggregate consideration of Rs. 10,37,000/- in cash, in contravention of section 269SS of the Act. Penalty proceedings under section 271D of the Act were initiated but later dropped by the Assessing Officer on 28.10.2022. The Principal Commissioner of Income Tax (PCIT) set aside the penalty order on 26.03.2025, invoking revisionary jurisdiction under section 263 of the Act. The assessee appealed against this order.…

Legal Issues

• 1. Whether the PCIT was justified in invoking revisionary jurisdiction under section 263 of the Act in respect of the order passed by the Assessing Officer.

Judgment Outcome

Decided in favour of Assessee.

Precedents Relied Upon

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