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INCOME TAX APPELLATE TRIBUNAL (DELHI BENCH)
S. Rifaura Rahman, AM, Anubhav Sharma, JM
Ashok Kumar Jain – Appellant
Versus
Pr. CIT-20 – Respondent
| Table of Content |
|---|
| 1. assessment by the pr. cit revised due to bogus purchases from non-existent entities. (Para 1 , 2) |
| 2. assessee challenges both the revisional order and original assessment. (Para 3 , 4) |
| 3. original assessment's legality can be examined in the appeal against section 263. (Para 5 , 6 , 7 , 8) |
| 4. void assessments cannot be the subject matter of revision. (Para 9) |
ORDER
PER ANUBHAV SHARMA, JM:
This is an appeal preferred by the assessee against the order dated 29.03.2025 of the Pr. Commissioner of Income-tax, Delhi-20 (hereinafter referred as Ld. PCIT) u/s 263 of the Income Tax Act, 1961 (hereinafter referred as ‘the Act’) revising the order dated 16.03.2023 passed by the AO u/s 147 r.w.s. 144 r.w.s. 144B of the Act.
2. Heard and perused the records. On examination of assessment records, Ld. PCIT, as revisional authority exercising powers u/s 263 of the Act, observed that the AO had received information from CBIC that M/s RCI Industries and Technologies Ltd were involved in the practice of availing/ issuing bogus sales/ purchase bills. A list of beneficiaries to whom such bills were issued was also shared with the AO and from the said list, it was found by AO that the asse
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