https://www.taxtmi.com/caselaws?id=772297 ITAT Chandigarh held that amounts paid by buyer directly to third-party confirming entity did not constitute consideration accruing to assessee for capital gains computation under Section 48. Assessee received consideration through banking channels with TDS deducted, satisfying real income test. Third-party had pre-existing contractual rights and was genuine stakeholder, not mere intermediary. PCIT's second Section 263 revision without fresh material constituted impermissible change of opinion. No tax leakage occurred as amounts were taxed in third-party's hands. Appeal allowed. en-us Wed, 04 Jun 2025 00:00:00 +0530 Fri, 06 Jun 2025 08:30:44 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=772297 ITAT Chandigarh held that amounts paid by buyer directly to third-party confirming entity did not constitute consideration accruing to assessee for capital gains computation under Section 48. Assessee received consideration through banking channels with TDS deducted, satisfying real income test. Third-party had pre-existing contractual rights and was genuine stakeholder, not mere intermediary. PCIT's second Section 263 revision without fresh material constituted impermissible change of opinion. No tax leakage occurred as amounts were taxed in third-party's hands. Appeal allowed. Case-Laws Income Tax Wed, 04 Jun 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=772297