The Income Tax Appellate Tribunal (ITAT) Delhi Bench ‘E’ delivered a crucial judgment on May 4, 2022, in the case of Mankameshwar Steels Pvt Ltd vs. Principal Commissioner of Income Tax (Pr. CIT), Aligarh, pertaining to the assessment year 2015-16. This appeal was noteworthy for its focus on the scrutiny of significant financial issues under the Income Tax Act, 1961.
Mankameshwar Steels Pvt Ltd, represented by advocate Vivek Bansal, appealed against the order dated March 14, 2019, issued by the Pr. CIT, Aligarh. The primary contention involved the reassessment of share application money amounting to Rs. 27,50,000 and income from commodity trading totaling Rs. 6,65,75,000. This reassessment was initially directed under section 263 of the Income Tax Act, instructing a fresh assessment to ensure accurate tax liability determination.
The tribunal’s proceedings highlighted procedural aspects relevant to the reassessment under section 263, which allows the CIT to revise any order deemed erroneous insofar as it is prejudicial to the interests of the revenue. The appellant argued that the subsequent reassessment did not result in any additional tax liabilities, thus rendering the appeal infructuous.
The ITAT, upon hearing the arguments, allowed the condonation of a delay of six days in filing the appeal and accepted the withdrawal of the case by the appellant. The decision emphasized the tribunal’s role in ensuring that reassessments are conducted fairly and in accordance with the law, particularly when significant amounts of income and tax implications are involved.
The case of ITA 5071/DEL/2019 serves as an important precedent in understanding the application of section 263 and its impact on corporate tax assessments. It highlights the processes involved in challenging and resolving tax disputes through the tribunal, providing insights into the dynamics of tax litigation and compliance.
Manage the increasing number of hearings effortlessly by leveraging the legal AI revolution We are India's Leading revolutionary AI-powered legal platform where you can get enough insights into top cases and judgements.
Research Platform