ITAT Delhi: No Material to Reopen Mukul Rohatgi’s ₹133.46 Crore Assessment

The ITAT Delhi held that revisional powers under Section 263 cannot be exercised in the absence of material showing error and prejudice to Revenue, and set aside the revision against Senior Advocate Mukul Rohatgi.

The case concerned a revision order passed by the Principal Commissioner of Income Tax for Assessment Year 2020-21, where Rohatgi’s income was assessed at ₹133.46 crore.

The Tribunal found that the Assessing Officer had examined issues relating to mutual fund capital gains, annual letting value of properties in India and abroad. 

It held that once a plausible view is taken after considering records, the assessment cannot be reopened merely because another view is possible. The revision was quashed. 

[Mukul Rohatgi v. Principal Commissioner of Income Tax]