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2026 Supreme(Online)(ITAT) 13224

INCOME TAX APPELLATE TRIBUNAL (NAGPUR BENCH)
Pawan Singh, Judicial Member, Khettra Mohan Roy, Accountant Member
Rajesh Krushnarao Chikte – Appellant
Versus
Pr.Cit, Nagpur – Respondent


Advocates:
For the Appellants/Petitioners: K.M. Gupta
For the Respondents: Pankaj Kumar

Table of Content
1. initiation of appeal and background facts of reassessment. (Para 1 , 2 , 3)
2. dual contentions on revisionary power due to alleged lack of inquiry. (Para 4 , 5 , 6)
3. non-application of mind on material issues justifies section 263 revision. (Para 7 , 8)

O R D E R

PER KHETTRA MOHAN ROY, AM:

This appeal filed by the assessee is directed against the order of Ld. Principal Commissioner of Income Tax, Nagpur-1, (for short, “PCIT”), dated 24/03/2025 passed under section 263 of the Income Tax Act, 1961 (for short, “Act”) for Assessment Year 2015-16.

2. The assessee has raised the following grounds of appeal:

1. That on the facts and circumstance of the case and in law, order dated 24 March 2025, passed under section 263 of the Income tax Act, 1961 ("the Act") by Hon'ble Principal Commissioner of Income Tax, Nagpur-1 is bad in law and liable to be quashed.

2. That, on the facts and circumstances of the case and in law, Hon'ble PCIT, Nagpur-1 has erred in initiating revisionary proceedings on the ground that subject issues have not been examined properly by Assessing Officer during course of assessment proceedings.

3. That, on the facts and in circumstances of the case as

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