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INCOME TAX APPELLATE TRIBUNAL (DELHI BENCH)
Yogesh Kumar, Judicial Member, Amitabh Shukla, Accountant Member
Shalimar Corp Ltd. – Appellant
Versus
PCIT, Central-3 – Respondent
| Table of Content |
|---|
| 1. condonation of delay in filing appeals (Para 1 , 2 , 3) |
| 2. assessee challenges pcit's section 263 jurisdiction (Para 4 , 5 , 6) |
| 3. tribunal precedents barring 263 after 153d approval (Para 7 , 8) |
| 4. pcit must examine 153d approval validity for 263 (Para 9) |
| 5. quashing pcit's 263 order due to lack of jurisdiction (Para 10 , 11 , 12) |
ORDER
PER AMITABH SHUKLA, AM,
These two appeals filed by the assessee are against orders both dated 31.03.2024 of learned Principal Commissioner of Income Tax, New Delhi, [hereinafter referred to as ‘ld. PCIT] passed under section 263 of the Income Tax Act, 1961 pertaining to Assessment Year and 2013-14 and 2014-15. The word ‘Act’ herein this order would mean Income Tax Act, 1961.
2. As both the appeals are on the commons issue of exercise of revisionary authority under section 263 of the Act by the PCIT, for the purposes of convenience both the appeals were heard together and are being adjudicated by this common order. Since, facts are identical, decision taken in ITA No.1546/Del/2025 shall apply mutatis mutandis in ITA No.1548/Del/2025.
3. At the outset, we have noted that the Registry had identified delay of 286 days in filing of appeal for
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