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Case Law Details

Case Name : Nanak Chand & Co. Vs PCIT (ITAT Delhi)
Appeal Number : I.T.A. No. 904/DEL/2022
Date of Judgement/Order : 30/08/2023
Related Assessment Year : 2017/18
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Nanak Chand & Co. Vs PCIT (ITAT Delhi)

In a recent decision, the Income Tax Appellate Tribunal (ITAT) in Delhi ruled that a difference of opinion alone is insufficient to invoke Section 263 of the Income Tax Act. The case involved a revisional order passed by the Principal Commissioner of Income Tax (Pr.CIT) concerning the assessment order for the assessment year 2017-18.

Background:

The assessee had e-filed its income tax return for Assessment Year 2017-18, declaring a taxable income of Rs. 1,75,930. The return was selected for scrutiny assessment, with the primary issue being the verification of cash deposits made during the demonetization period.

After the completion of the assessment, the Pr.CIT exercised revisional powers under Section 263 of the Income Tax Act, deeming the assessment order to be erroneous and prejudicial to the interest of the revenue. The Pr.CIT issued a show-cause notice to the assessee, pointing out alleged discrepancies in the assessment.

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