https://www.taxtmi.com/caselaws?id=767780 ITAT Delhi set aside PCIT's revision order u/s 263 regarding deduction u/s 54 and application of section 50C. The tribunal held that AO had already allowed the claimed deduction of Rs. 5 crores in compliance with earlier directions, making further disallowance tantamount to double taxation since assessee offered it for tax in AY 2021-22 after failing to invest within prescribed time. Regarding section 50C application, ITAT ruled AO lacked jurisdiction to examine issues beyond limited scrutiny scope without proper approval from higher authorities as per CBDT Instruction 20/2015. The assessment order was not erroneous or prejudicial to revenue interest, warranting setting aside of revision order. en-us Fri, 21 Mar 2025 00:00:00 +0530 Tue, 25 Mar 2025 08:48:17 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=767780 ITAT Delhi set aside PCIT's revision order u/s 263 regarding deduction u/s 54 and application of section 50C. The tribunal held that AO had already allowed the claimed deduction of Rs. 5 crores in compliance with earlier directions, making further disallowance tantamount to double taxation since assessee offered it for tax in AY 2021-22 after failing to invest within prescribed time. Regarding section 50C application, ITAT ruled AO lacked jurisdiction to examine issues beyond limited scrutiny scope without proper approval from higher authorities as per CBDT Instruction 20/2015. The assessment order was not erroneous or prejudicial to revenue interest, warranting setting aside of revision order. Case-Laws Income Tax Fri, 21 Mar 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=767780