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ITAT upheld revision proceedings u/s 263 regarding undisclosed property transactions discovered during recovery proceedings. The assessee had failed to report capital gains from three properties and subsequently acknowledged these transactions. Though initially captioned as a proposal u/s 263, the AO's information was deemed valid grounds for PCIT's intervention. The jurisdictional challenge regarding PCIT-21 versus PCIT-12's authority was rejected, as current jurisdiction lay with PCIT-12 when proceedings were initiated on 22.02.2021. The assessee's prior agreement to settle and subsequent failure to provide documentation within the stipulated timeframe further supported PCIT's findings. Appeal dismissed.
ITAT upheld revision proceedings u/s 263 regarding undisclosed property transactions discovered during recovery proceedings. The assessee had failed to report capital gains from three properties and subsequently acknowledged these transactions. Though initially captioned as a proposal u/s 263, the AO's information was deemed valid grounds for PCIT's intervention. The jurisdictional challenge regarding PCIT-21 versus PCIT-12's authority was rejected, as current jurisdiction lay with PCIT-12 when proceedings were initiated on 22.02.2021. The assessee's prior agreement to settle and subsequent failure to provide documentation within the stipulated timeframe further supported PCIT's findings. Appeal dismissed.
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