Rico Auto Industries Limited Vs PCIT (ITAT Chandigarh)
In these two appeals concerning Assessment Years (AY) 2020–21 and 2021–22, the assessee challenged the revisionary orders passed under Section 263 by the Principal Commissioner of Income Tax (Pr. CIT), Ludhiana-1. The facts for both years were identical, and the Tribunal first examined AY 2020–21. The assessee opposed the invocation of revisionary jurisdiction, asserting that the Assessing Officer (AO) had already examined all relevant issues in detail during the original scrutiny assessment completed under Section 143(3) read with Section 144B.
For AY 2020–21, the case records showed that the assessee’s return was subjected to complete scrutiny, and the AO had identified ten specific issues for verification, including deductions claimed under various sections, increases in unsecured loans, refund claims, business loss set-off, liabilities, losses from currency fluctuations, differences in stock values, additions to intangible assets, and high refund out of advance tax. Multiple notices under Section 142(1) were issued with detailed questionnaires, and the assessee filed comprehensive replies with supporting documents. The AO carried out several rounds of enquiry, including show-cause notices, and considered the assessee’s responses before finalizing the assessment. Apart from making disallowances under Sections 35(2AB) and 14A, the AO accepted the returned loss after being satisfied with explanations on all other issues.
