https://www.taxtmi.com/caselaws?id=761263 Delhi HC held that PCIT lacked jurisdiction to pass revision order u/s 263 where AO had accepted assessee's explanation regarding share purchase transaction during reassessment proceedings. Court ruled that once AO was satisfied with assessee's justification for FDPL share investment and APPL borrowing, AO could not make additions on other grounds. PCIT's attempt to add income u/s 68 for transaction not covered under reopening reasons was invalid. Powers u/s 263 require order to be both erroneous and prejudicial to revenue. Since AO's acceptance of explanation was reasonable, PCIT could not fault AO for not making additions or conducting further enquiries regarding TDS-income mismatch. Petition decided in favor of assessee. en-us Mon, 21 Oct 2024 00:00:00 +0530 Thu, 07 Nov 2024 08:47:58 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=761263 Delhi HC held that PCIT lacked jurisdiction to pass revision order u/s 263 where AO had accepted assessee's explanation regarding share purchase transaction during reassessment proceedings. Court ruled that once AO was satisfied with assessee's justification for FDPL share investment and APPL borrowing, AO could not make additions on other grounds. PCIT's attempt to add income u/s 68 for transaction not covered under reopening reasons was invalid. Powers u/s 263 require order to be both erroneous and prejudicial to revenue. Since AO's acceptance of explanation was reasonable, PCIT could not fault AO for not making additions or conducting further enquiries regarding TDS-income mismatch. Petition decided in favor of assessee. Case-Laws Income Tax Mon, 21 Oct 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=761263