https://www.taxtmi.com/caselaws?id=760049 The ITAT Hyderabad allowed the assessee's appeal against PCIT's revision order u/s 263. PCIT had concluded the assessment order was erroneous and prejudicial to revenue, arguing that AO failed to examine potential gains u/s 56(2)(viia) regarding share buyback transactions. The tribunal held that PCIT's conclusion was based on hypothetical possibilities regarding DCF method adoption. Since share issuance and buyback constitute capital transactions resulting in capital receipts, they fall outside the ambit of section 56. The tribunal found no basis for PCIT's revisionary jurisdiction, ruling the assessment order was not prejudicial to revenue interests. en-us Wed, 09 Oct 2024 00:00:00 +0530 Mon, 14 Oct 2024 12:34:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=760049 The ITAT Hyderabad allowed the assessee's appeal against PCIT's revision order u/s 263. PCIT had concluded the assessment order was erroneous and prejudicial to revenue, arguing that AO failed to examine potential gains u/s 56(2)(viia) regarding share buyback transactions. The tribunal held that PCIT's conclusion was based on hypothetical possibilities regarding DCF method adoption. Since share issuance and buyback constitute capital transactions resulting in capital receipts, they fall outside the ambit of section 56. The tribunal found no basis for PCIT's revisionary jurisdiction, ruling the assessment order was not prejudicial to revenue interests. Case-Laws Income Tax Wed, 09 Oct 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=760049