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2025 Supreme(Online)(ITAT) 8012

INCOME TAX APPELLATE TRIBUNAL (AHMEDABAD BENCH)
MAKARAND V.MAHADEOKAR, AM, SANJAY GARG, JM
Aahana Sales Private Limited – Appellant
Versus
Pr.CIT(Central) – Respondent


Advocates:
For the Appellants/Petitioners: Shri Vivek Chavda, AR
For the Respondents: Shri R.P. Rastogi, CIT-DR

Table of Content
1. facts concerning taxpayer's reassessment and pcit's revision. (Para 2)
2. arguments around adequacy of inquiry and statutory obligations. (Para 3 , 4)
3. court's views on procedural necessities under section 263. (Para 5)
4. final outcome quashing the pcit's order. (Para 6)

आदेश/ORDER

PER MAKARAND V.MAHADEOKAR, AM:

The present appeal has been preferred by the assessee against the order dated 26.03.2025 passed under section 263 of the Income Tax Act, 1961 [hereinafter referred to as “the Act”] by the Principal Commissioner of Income Tax (Central), Ahmedabad [hereinafter referred to as “the PCIT”] for the Assessment Year 2018-19. The impugned revisionary order arises from the reassessment order passed by the Assessing Officer on 30.03.2023 under section 147 read with sections 144 and 143(3) of the Act.

2. Facts of the Case

2.1 The assessee filed its return of income for the year under consideration on 28.09.2018 declaring total income at Rs. NIL, which was processed under section 143(1). Subsequently, on the basis of information disseminated on the Insight Portal, the Assessing Officer initiated reassessment proceedings and issued notice under section 148 on 30.03.2022.

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