This compilation indexes 12 rulings — 10 from various benches of the Income Tax Appellate Tribunal (ITAT) and 2 from High Courts — that engage Section 263(1) of the Income Tax Act, 1961. The rulings span April 2022 to August 2026 and arise across multiple jurisdictions including Raipur, Patna, Pune, Chandigarh, Mumbai, Amritsar, Cuttack, and the Gujarat and Punjab-Haryana High Courts. The compilation is intended for in-house tax teams, Big-4 associates, and law firm researchers who require a structured reference index of Section 263(1) proceedings, covering a range of assessee types, assessment years, and accompanying sections.

Research index only. This page is a structured case-law reference tool, not legal or tax advice. Readers should verify all citations against full judgments and check for subsequent stays, reversals, or appeals before relying on any ruling.

The statutory framework in one paragraph

Section 263(1) of the Income Tax Act, 1961 empowers the Principal Commissioner or Commissioner of Income Tax (PCIT/CIT) to call for and examine the record of any proceeding under the Act and, if satisfied that any order passed by the Assessing Officer is erroneous insofar as it is prejudicial to the interests of the Revenue, to pass such orders thereon as the circumstances of the case justify, including an order enhancing or modifying the assessment or cancelling the assessment and directing a fresh assessment. The revisionary authority must record reasons in writing before exercising this power. The section thus constitutes a supervisory check within the income-tax administration, enabling higher authorities to correct orders that are both erroneous and prejudicial to Revenue — both conditions being required to be satisfied simultaneously for valid exercise of jurisdiction.

The 12 rulings

1. M/S Ganesh Prasad Khetan vs PCIT, Raipur-1, Raipur

Bench: Income Tax Appellate Tribunal - Raipur
Date: 6 August 2026
Sections engaged: 263(1)
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal, registered as ITA No. 430/RPR/2026, was filed by the assessee against the order of the Pr. CIT, Raipur-1 dated 19.03.2026 for the assessment year 2022-23. The source preview is primarily procedural and does not disclose the substantive grounds or the tribunal's final determination on the revisionary order.

2. Jyoti Awadhiya, Raipur vs PCIT-1, Raipur, Raipur

Bench: Income Tax Appellate Tribunal - Raipur
Date: 31 July 2026
Sections engaged: 263(1)
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal, registered as ITA No. 377/RPR/2026, was preferred by the assessee against the order of the Pr. CIT, Raipur-1 dated 25.03.2026 for the assessment year 2017-18. The source preview is procedural in nature and does not disclose the substantive grounds or the tribunal's final finding on the validity of the revisionary order.

3. Crest Steel And Power Private vs PCIT, Central Circle, Bhopal, Bhopal

Bench: Income Tax Appellate Tribunal - Raipur
Date: 31 July 2026
Sections engaged: 139(3), 238, 263(1)
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal, registered as ITA No. 308/RPR/2026, was filed by the assessee — Crest Steel and Power Private Limited — against an order for the assessment year 2022-23. The case involves sections relating to filing of returns and refund entitlements alongside the revisionary provision. The source preview is primarily procedural and does not disclose the substantive determination made by the tribunal.

4. South Bihar Power Distribution Co vs Pr. CIT-1, Patna

Bench: Income Tax Appellate Tribunal - Patna
Date: 30 April 2026
Sections engaged: 263(1), 37
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal, registered as ITA No. 181/PAT/2022, was filed by the assessee against the order of the Pr. CIT, Patna-1 dated 17.03.2022 (Order No. 1022454560(1)) passed under Section 263 of the Act for the assessment year 2017-2018. The assessee filed its return of income on 31.10.2017. The source preview references a large value claim of refund as one of the issues noted in the proceeding; the substantive outcome of the tribunal's adjudication is not disclosed in the available preview.

5. Meenamani Ganga Builder Llp, Pune vs PCIT (Central), Pune, Pune

Bench: Income Tax Appellate Tribunal - Pune
Date: 21 April 2025
Sections engaged: 263(1)
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal, registered as ITA No. 1027/PUN/2024, pertains to the assessment year 2019-20 and was directed against the order dated 12.03.2024 passed by the PCIT (Central), Pune under Section 263. The assessee is a Limited Liability Partnership engaged in Real Estate business; a search under Section 132 of the Act had been conducted on 10.01.2019, and the assessee e-filed its return of income on 30.09.2020. The source preview does not disclose the tribunal's final determination on the revisionary order.

6. Indo Pacific Finlease Ltd, Chandigarh vs PCIT-Chandigarh 1, Chandigarh

Bench: Income Tax Appellate Tribunal - Chandigarh
Date: 16 April 2025
Sections engaged: 148, 149, 263(1)
Outcome: Outcome not specified in source
Procedural / substantive ground: Both appeals — ITA Nos. 448 & 449/CHD/2024 — were filed by the assessee against separate orders of the Pr. CIT, Chandigarh-1 dated 28.03.2024 and 23.03.2024 under Section 263 for the assessment years 2014-15 and 2015-16. The assessee, in response to a show cause notice issued under Section 263(1), raised various pleas challenging the legal validity of the notice and submitted that the notice was not tenable; the source preview does not disclose the tribunal's final ruling.

7. Om Sai Housing & Development Co. P. Ltd vs Pr. CIT-8, Mumbai

Bench: Income Tax Appellate Tribunal - Mumbai
Date: 15 February 2023
Sections engaged: 263(1)
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal, registered as ITA No. 635/MUM/2021, relates to assessment year 2015-16. The source preview discloses that various parties and amounts appear in the record — including transactions with entities engaged in pharmaceutical and real estate businesses — which appear to form part of the factual matrix before the tribunal. The source preview does not disclose the tribunal's substantive determination on the revisionary order.

8. Hoshiarpur Traders, Hoshiarpur vs Principal Commissioner Of Income Tax

Bench: Income Tax Appellate Tribunal - Amritsar
Date: 11 November 2022
Sections engaged: 263(1)
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal, registered as I.T.A. No. 117/Asr/2022, relates to the assessment year 2017-18. The source preview discloses a factual matrix involving unsecured creditor transactions — including amounts taken and returned by several named creditors — which appear to form part of the record examined in the revisionary proceedings. The source preview does not disclose the tribunal's final determination.

9. Ganesh Ores Pvt. Ltd., Rourkela vs Principal CIT, Sambalpur

Bench: Income Tax Appellate Tribunal - Cuttack
Date: 14 September 2022
Sections engaged: 263(1), 292B
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal, registered as ITA No. 08/CTK/2022, was filed by the assessee against the order of the Pr. CIT, Sambalpur passed under Section 263 of the Act dated 24.02.2020 for the assessment year 2015-16. The appeal was noted to be time-barred by 169 days; the assessee filed a condonation petition dated 21.01.2022 explaining the delay. The source preview does not disclose the tribunal's substantive determination on the revisionary order or the condonation.

10. Alpabala Dilipkumar Sabwa vs State Of Gujarat

Bench: Gujarat High Court
Date: 9 September 2022
Sections engaged: 263(1)
Outcome: Outcome not specified in source
Procedural / substantive ground: The petition, registered as R/Special Civil Application No. 12460 of 2022, was filed before the Gujarat High Court at Ahmedabad by the petitioners feeling aggrieved by and dissatisfied with an impugned order. The source preview is largely procedural and does not disclose the substantive grounds of challenge or the High Court's final ruling on the matters pertaining to Section 263(1).

11. Amritsaria Mal Jain And Sons vs Principal Commissioner Of Income Tax

Bench: Punjab-Haryana High Court
Date: 15 July 2022
Sections engaged: 263(1), 143(3)
Outcome: Outcome not specified in source
Procedural / substantive ground: The writ petition, registered as CWP-4909-2022 (O&M), challenged a show cause notice issued under Section 263(1) for the assessment year 2017-18, whereby the revisional authority asked the petitioner to show cause as to why the order passed under Section 143(3) should not be revised. The petitioner, a partnership firm, had filed a return for the assessment year 2017-18 on 02.11.2017 declaring an income of Rs. 30,78,270/-, which included a voluntarily surrendered amount of Rs. 30 lakhs disclosed as an increase in closing stock and capital accounts of the partners following a survey at its premises on 19.09.2016.

12. M/S. Prachi Agriculture & Properties vs Pr. CIT-1, Raipur

Bench: Income Tax Appellate Tribunal - Raipur
Date: 21 April 2022
Sections engaged: 263(1), 68
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal, registered as ITA No. 30/RPR/2021, was filed against the revisionary order of the PCIT, Raipur-1 passed under Section 263 of the Act dated 26.03.2021 for the assessment year 2016-2017. The grievance raised in the appeal was described as twofold, firstly challenging the violation of the principle of natural justice; the case also engaged Section 68 relating to unexplained cash credits. The source preview does not disclose the tribunal's final determination.

Patterns across these 12 rulings

Widespread geographic spread of Section 263(1) litigation. The rulings come from ITAT benches at Raipur, Patna, Pune, Chandigarh, Mumbai, Amritsar, and Cuttack, as well as from the Gujarat and Punjab-Haryana High Courts, indicating that challenges to revisionary orders under Section 263(1) arise uniformly across jurisdictions rather than being concentrated in any single circuit.
Revisionary orders frequently challenged by assessees via ITAT. In all 12 cases, it is the assessee who is the appellant or petitioner challenging the exercise of revisionary jurisdiction by the PCIT/CIT — a consistent pattern suggesting that Section 263(1) orders routinely face appellate scrutiny after being issued by the revisional authority.
Section 263(1) often accompanies other substantive sections. Several cases in this compilation engage Section 263(1) alongside other provisions — such as Section 37 (Case 4), Sections 139(3) and 238 (Case 3), Sections 148 and 149 (Case 6), Section 292B (Case 9), Section 68 (Case 12), and Section 143(3) (Case 11) — indicating that the revisionary proceedings frequently arise in the context of disputes over deductibility, unexplained credits, refund entitlements, and the validity of reassessment-related steps.
Procedural challenges feature alongside substantive ones. In at least one case (Case 6), the assessee raised pleas in response to the Section 263(1) show cause notice asserting that the notice itself was not legally valid. In Case 9, the appeal was time-barred by 169 days requiring a condonation petition. In Case 11, the challenge was mounted at the High Court level via writ petition against the show cause notice itself — illustrating that Section 263(1) challenges span procedural as well as substantive grounds.
Outcome data is limited across the corpus. All 12 rulings in this compilation carry "Outcome not specified in source" as the recorded outcome direction. Researchers should access the full text of each judgment to determine the disposal and any directions issued by the tribunal or court.

How to use this compilation

This index is designed as a starting point for legal research, not a substitute for reading the full text of each judgment. Each case entry identifies only the information available in the structured source data — ITA/case numbers, assessment years, parties, bench, date of pronouncement, and sections engaged. Researchers should retrieve the complete order from indiankanoon.org, official ITAT portals, or court websites to review the detailed reasoning, the specific grounds on which the revisionary order was upheld or quashed, and any directions for fresh assessment or other relief.

Before relying on any ruling in this compilation, researchers should verify whether the order has been stayed, appealed further, or reversed by a superior forum. ITAT decisions may be appealed to the relevant High Court under Section 260A, and High Court decisions may be appealed to the Supreme Court. It is also advisable to check whether the CBDT has issued any circular, instruction, or clarification relevant to the legal position engaged in the ruling, as departmental instructions can affect how Section 263(1) proceedings are initiated and conducted.

This compilation does not purport to be exhaustive of all Section 263(1) rulings in the cited period. The cases indexed here are drawn from a structured corpus and are subject to the availability and completeness of source data. Tax professionals and researchers requiring comprehensive coverage of Section 263(1) jurisprudence should supplement this index with searches on official court portals and subscription-based legal databases.

Source

All cases listed above are drawn from the TaxNoticeAI structured legal corpus (16,101 Indian tax judgments, CBIC circulars, ITAT rulings, AAR rulings, GSTAT rulings), sourced from indiankanoon.org and official court portals.

Section 263(1) Revisionary Powers: 12 ITAT & HC Rulings (2022–2026)