Case Law Details
Vijay Rajnikant Patel Vs PCIT (ITAT Ahmedabad)
The case of Vijay Rajnikant Patel Vs PCIT before the Income Tax Appellate Tribunal (ITAT) Ahmedabad concerns the interpretation of Section 263 revisionary powers under the Income Tax Act, 1961. The appellant, Vijay Rajnikant Patel, challenged the order dated 25.03.2023 passed by the Learned Principal Commissioner of Income Tax-3, Ahmedabad, under Section 263 of the Act.
The grounds of appeal raised by the assessee primarily questioned the legality of the revisionary order, contending that it was not justified in the context of the limited scrutiny assessment conducted under the e-assessment scheme for Assessment Year 2018-19.
The essence of the matter revolved around the revision initiated by the Principal Commissioner concerning the adequacy of agricultural expenses claimed by the assessee. Despite the assessment being conducted under limited scrutiny, the Principal Commissioner sought to revise the assessment order, asserting inadequacy in verifying agricultural receipts and expenses.
The appellant argued that the Principal Commissioner’s jurisdiction under Section 263 should be confined to issues considered in the limited scrutiny assessment, as per CBDT instructions. Several precedents were cited to support this contention, emphasizing the principle that revisionary powers cannot extend beyond the scope of issues addressed in limited scrutiny.
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