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INCOME TAX APPELLATE TRIBUNAL (CHENNAI BENCH)
PADMAVATHY.S, Accountant Member, MANU KUMAR GIRI, Judicial Member
Pratipa Cashews – Appellant
Versus
The Dy. Commissioner of Income Tax, Vadakailasam, Panruti, Circle-1, Cuddalore – Respondent
| Table of Content |
|---|
| 1. appeal against pcit's revision u/s 263 for inadequate purchase verification. (Para 1 , 2) |
| 2. condonation of 256-day delay in filing appeal granted. (Para 3) |
| 3. ao conducted adequate enquiry on bogus purchases via notices. (Para 4 , 5) |
| 4. judicial precedents: inadequate enquiry doesn't justify s.263 revision. (Para 6) |
| 5. twin conditions for s.263: ao's enquiry sufficient, pcit overreach. (Para 7 , 8) |
| 6. pcit order set aside; assessee's appeal allowed. (Para 9) |
आदेश/ORDER
PER PADMAVATHY.S, A.M:
This appeal by the assessee is against the order of the Principal Commissioner of Income Tax, Chennai-3 (in short "PCIT") passed u/s. 263 of the Income Tax Act, 1961 (in short "the Act") dated 12.03.2025 for Assessment Year (AY) 2021-22. The assessee raised the following grounds of appeal:
“1. The order of the learned Assessing Officer Is Contrary to law and Facts and Circumstance of the case.
2. The Ld AO failed to appreciate the evidence submitted in course of assessment proceedings and assessed certain purchase as not genuine and assessed as unexplained expenditure.
3. The LD AO without considering the evidence in support of the expenditure submitted, failed to see the merit of the
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