2026 (5) TMI 1478

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....l Dahiya, Adv. For the Respondent: Sh. Sanjeev Kaushal, CIT, DR ORDER PER ANUBHAV SHARMA, JM: This appeal is preferred by the Assessee against the order u/s. 263 of the Income Tax Act 1961, dated 07.03.2025 of the Principal Commissioner of Income Tax-4, Delhi (hereinafter referred as Ld. First Appellate Authority or in short Ld. 'Revisionary Authority') DIN & Order No : ITBA/REV/F/REV5....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....mpugned order u/s. 263 of the Act has been challenged before us by raising following grounds: "1.  That having regard to facts & circumstances of the case, Ld. Pr. CIT has erred in law and on facts in assuming jurisdiction u/s. 263 qua assessment order passed u/s. 143(3) r.w.s. 144B dated 21.09.2022 and has further erred in holding that the said assessment order is erroneous and prej....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

.... 5. That in any view of the matter and in any case, the impugned order passed u/s. 263 by Ld. Pr. CIT is barred by limitation, void-ab-initio, bad in law and against the facts of the case and in gross violation of principles of natural justice. 6. That the appellant craves the leave to add, amend, modify, delete any of the grounds of appeal before or at the time of hearing and all the a....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....roacha Stock Broking Pvt. Ltd. Vs. PCIT-4, ITA No. 2718/Mum/2025, dated 23.06.2025 (Mum-Trib) & The Rubi Mills Limited Vs. PCIT, ITA No. 3035/Del/2025, dated 27.06.2025 (Mum-Trib). 5. Since, the issue under consideration in proceedings u/s. 263 of the Act is settled to be in favour of the assessee by catena of judicial decisions including JMS Mining (P) Ltd. vs PCIT (2021), 130 taxmann.com 118 ....