Sunayana Investment Company Ltd. vs. PCIT-1, Indore

Parties Involved

Facts Summary

The assessee, Sunayana Investment Company Ltd., appealed against the revision order dated 11.03.2024 passed by the Principal Commissioner of Income Tax, Indore-1 under Section 263 of the Income Tax Act for the Assessment Year 2017-18. The assessee contested the order on several grounds, including that the order was passed without any material evidence and was in contravention of the law. The assessee argued that the reassessment proceedings were void as they were based on the recommendation of the Assessing Officer. The Assessing Officer had already considered the issue of accommodation entries during the original assessment and found no transaction. The Principal Commissioner of Income Tax invoked Section 263 of the Act based on information from the INSIGHT portal, which the assessee denied receiving.…

Legal Issues

• 1. Whether the order passed by the Principal Commissioner of Income Tax under Section 263 of the Act is bad in law and illegal?
• 2. Whether the reassessment proceedings initiated by the Assessing Officer are void ab initio?

Judgment Outcome

Decided in favour of Assessee.

Precedents Relied Upon

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