Sheetal Dattatray Patil Vs PCIT (ITAT Mumbai Bench)
Ignorance Cannot Rewind the Revision Clock: ITAT Refuses 689-Day Delay Against Section 263 Order After Consequential Assessment Completed a Full Appellate Round
Facts of the Case
The assessee’s original assessment was completed u/s 143(3) r.w.s. 144B on 18.04.2021, determining total income at ₹11,36,910. This included an addition of ₹4,21,960 u/s 56(2)(x).
The PCIT subsequently examined the assessment record & found that the AO had allegedly failed to conduct the required inquiry regarding the complete source of funds used for purchasing an immovable property valued at ₹37 lakh.
Accordingly, the PCIT invoked revisionary jurisdiction u/s 263 & passed an order dated 30.03.2024 setting aside the original assessment for fresh examination.
Pursuant to the revisionary order, the AO completed a consequential assessment after examining the source of investments made by the assessee & the assessee’s spouse, including an amount of ₹24 lakh. The total income was enhanced to ₹50,60,660.
Consequential Assessment Already Appealed
The assessee challenged the consequential assessment before the first appellate authority, which confirmed the addition.
Thereafter, the assessee approached the ITAT in ITA No. 963/Mum/2026. By order dated 13.05.2026, the Tribunal restored the assessment to the AO for de novo adjudication.
