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ITAT allowed assessee's appeal challenging PCIT's revision order under section 263. The AO had reopened assessment under section 147 regarding Rs. 11 lacs income, which was satisfactorily explained by assessee after proper verification. PCIT directed AO to reassess other transactions of Rs. 50 lacs that came to PCIT's notice independently. ITAT held PCIT lacked jurisdiction to direct assessment of income not originally subject to section 147 proceedings, as AO's jurisdiction under section 147 is limited to specific income believed to have escaped assessment. Since AO had properly verified the Rs. 11 lacs transaction and accepted returned income, and the Rs. 50 lacs transactions were not part of original reassessment scope, PCIT's revision order was set aside for exceeding jurisdictional limits.
ITAT allowed assessee's appeal challenging PCIT's revision order under section 263. The AO had reopened assessment under section 147 regarding Rs. 11 lacs income, which was satisfactorily explained by assessee after proper verification. PCIT directed AO to reassess other transactions of Rs. 50 lacs that came to PCIT's notice independently. ITAT held PCIT lacked jurisdiction to direct assessment of income not originally subject to section 147 proceedings, as AO's jurisdiction under section 147 is limited to specific income believed to have escaped assessment. Since AO had properly verified the Rs. 11 lacs transaction and accepted returned income, and the Rs. 50 lacs transactions were not part of original reassessment scope, PCIT's revision order was set aside for exceeding jurisdictional limits.
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