2026 (7) TMI 421

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.... on 28.12.2019 for Assessment Year 2012-13. 2. Brief facts of the case are that the assessee is an individual and has declared Income from Business and Profession, and income from Other Sources during the year under consideration. The assessee filed its Original Return of income for the A.Y. 2012-13 electronically on 30.08.2012 declaring total income of Rs. 2,83,434/-. The return was processed u/s 143(1) on 24.11.2012. Thereafter, on the basis of information from investigation wing, Delhi that the assessee has provided accommodation entries amounting to Rs. 65,00,000/- during the F.Y. 2011-12 to Sh. Anand Kumar Jain and Sh. Naresh Kumar Jain and received cash in return, reassessment proceedings in the case of the assessee for A.Y. 2012-1....

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....7 taxmann.com 195 (Delhi Tribunal)] * Auro Iron Ltd. vs Principal Commissioner of Income Tax-l ([2025] 173 taxmann.com 365 (Jaipur Tribunal)] * Hotel Babylon Continental Pvt Ltd. vs Principal Commissioner of Income Tax (Central) ([2024] 164 taxmann.com 306 (Raipur Tribunal)] * Gulab Badgujar (HUF) vs The Commissioner of Income Tax (Central) (ITA No. 798 and 799/PUN/2015) (Pune Tribunal) * Shiv Vegpro Pvt Ltd vs The PCIT, Udaipur (ITA No. 1014/JPR/2024) (Jaipur Tribunal) 5. It is the say of the ld AR that the reassessment proceedings were on the issue of accommodation entries while the PCIT has invoked the proceedings u/s 263 on the issue of applicability of section 50C as the valuation of property by s....

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....[2007] 162 taxman 465 (SC)] squarely applies. The decision in the case of CIT vs Industrial Development Bank of India Ltd lays down the law as under: "3. At the outset, it is required to be noted and it is not in dispute that, as such, the commissioner exercised powers under section 263 of the Act with respect to the issues which were not covered in the reassessment proceedings. Therefore, the issue before the Commissioner while exercising the powers under Section 263 of the Act relate back to the original Assessment Order and, therefore, the limitation would start from the original Assessment Order and not from the Reassessment Order. We are fortified with our view by the decision of this Court in the case of CIT v. Alagendran Fin....