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2025 Supreme(Online)(ITAT) 7793

INCOME TAX APPELLATE TRIBUNAL (CHENNAI BENCH)
SHRI ABY T. VARKEY, JM, SHRI S.R.RAGHUNATHA, AM
M/s.Bannari Amman – Appellant
Versus
The PCIT, Educational Trust, Central Circle-3(2), Trichy Road – Respondent


Advocates:
For the Appellants/Petitioners:Mr.Vikram Vijayaraghavan, Advocate
For the Respondents: Ms.E. Pavuna Sundari, CIT

Table of Content
1. overview of the assessment scenario regarding the income trust. (Para 2 , 3)
2. arguments surrounding the conditions for invoking section 263. (Para 4)
3. court observations on jurisdiction and assessment validity. (Para 6 , 9)
4. the legal reasoning regarding the invalidity of revisional powers. (Para 10)
5. final ruling on the appeals. (Para 11)

ORDER

PER ABY T. VARKEY, JM:

These are appeals preferred by the assessee against the order of the Learned Principal Commissioner of Income Tax (Central), (hereinafter referred to as “the Ld.PCIT”), Chennai-1, dated 28.03.2025 for the Assessment Year (hereinafter referred to as "AY”) 2015-16 and order dated 26.03.2025 for AY 2016-17 exercising his revisional power u/s.263 of the Income Tax Act, 1961 (hereinafter referred to as "the Act”). Both sides agreed that the facts and issues involved in both the appeals are same and therefore, with the consent of both the parties, the facts pertaining to AY 2015-16 is taken as the lead case, result of which will be followed for AY 2016-17.

2. The brief facts pertaining to AY 2015-16 are that the assessment in the case of assessee’s trust was completed by the AO vide order dated 25.10.20

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