https://www.taxtmi.com/caselaws?id=445802 ITAT Chennai dismissed assessee's appeal challenging PCIT's revision order u/s 263. The tribunal held that section 263 contains no exclusion for search assessments u/s 153A/153C, rejecting assessee's argument that revision proceedings cannot be initiated for such assessments. Regarding seized documents showing sale agreement details, ITAT found AO failed to examine evidence properly and assessee provided no counter-evidence to establish the transaction was conducted personally rather than on company's behalf. However, in another matter, ITAT allowed assessee's appeal and quashed PCIT's revision order where AO had already examined expenses and formed a possible view after raising queries, making revision impermissible under established legal principles. en-us Fri, 11 Aug 2023 00:00:00 +0530 Mon, 20 Nov 2023 08:27:27 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=445802 ITAT Chennai dismissed assessee's appeal challenging PCIT's revision order u/s 263. The tribunal held that section 263 contains no exclusion for search assessments u/s 153A/153C, rejecting assessee's argument that revision proceedings cannot be initiated for such assessments. Regarding seized documents showing sale agreement details, ITAT found AO failed to examine evidence properly and assessee provided no counter-evidence to establish the transaction was conducted personally rather than on company's behalf. However, in another matter, ITAT allowed assessee's appeal and quashed PCIT's revision order where AO had already examined expenses and formed a possible view after raising queries, making revision impermissible under established legal principles. Case-Laws Income Tax Fri, 11 Aug 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=445802