Siddharth Bhaskar Shah vs PCIT -27

Judicial Analysis Court Copy Headnote Facts Arguments Court observation

INCOME TAX APPELLATE TRIBUNAL (MUMBAI BENCH)
Sandeep Gosain, Judicial Member, Om Prakash Kant, Accountant Member
Siddharth Bhaskar Shah – Appellant
Versus
PCIT -27 – Respondent

Advocates:
For the Appellants/Petitioners: Satyaprakash Singh
For the Respondents: Vivek Permapurna, CIT (DR)

Table of Content
1. assessee's grounds challenging pcit's section 263 revision on section 54f exemption. (Para 8 , 9)
2. factual background of capital gains, investments, and prior pcit revisions. (Para 10)

ORDER

Per: SHRI. SANDEEP GOSAIN, J.M.:

The present appeal has been filed by the assessee challenging the impugned order dt. 24.04.2025 passed under section 263 of the („the Act‟), by the Pr.CIT(A) for the assessment year 2022-23. The assessee has raised the following grounds of appeal:

1. The Learned Principal Commissioner of Income-tax has erred in law and on facts in not appreciating that where the A.O. after detailed verification of record and making enquires had framed the assessment, the revision powers conferred on the Principal CIT under section 263 of Act, cannot invoked only based on a change of opinion.

2. The Principal Commissioner of Income-tax has erred in passing Order u/s.263 of the Income-tax Act, 1961 dated 24.04.2025, without appreciating the fact that the order passed by the A.O. is neither erroneous nor prejudicial to the interest of revenue.

3. The Principal Commissioner of Income-tax has erred in passing Order u/s.263 of the Income-tax Act, 1961 dated 24.04.2025,

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INCOME TAX APPELLATE TRIBUNAL (MUMBAI BENCH)Sandeep Gosain, Judicial Member, Om Prakash Kant, Accountant MemberSiddharth Bhaskar Shah – AppellantVersusPCIT -27 – Respondent

Cases Referred (1)

INCOME TAX APPELLATE TRIBUNAL (MUMBAI BENCH)
Sandeep Gosain, Judicial Member, Om Prakash Kant, Accountant Member
Siddharth Bhaskar Shah – Appellant
Versus
PCIT -27 – Respondent