https://www.taxtmi.com/caselaws?id=772285 The ITAT Ahmedabad upheld the PCIT's revision order under Section 263, finding the AO's assessment erroneous and prejudicial to revenue. The case involved undisclosed income declared during a survey that was received in cash. The PCIT correctly determined that the AO failed to examine the applicability of Sections 69A read with 115BBE, 269ST, and 271DA. The tribunal held that merely disclosing and paying tax does not protect the assessee from Section 69A unless the source is satisfactorily explained with evidence. Since the AO conducted no independent inquiry about the nature and source of the undisclosed income, Explanation 2(a) to Section 263 applied. The assessee's appeals were dismissed. en-us Mon, 02 Jun 2025 00:00:00 +0530 Fri, 06 Jun 2025 08:30:44 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=772285 The ITAT Ahmedabad upheld the PCIT's revision order under Section 263, finding the AO's assessment erroneous and prejudicial to revenue. The case involved undisclosed income declared during a survey that was received in cash. The PCIT correctly determined that the AO failed to examine the applicability of Sections 69A read with 115BBE, 269ST, and 271DA. The tribunal held that merely disclosing and paying tax does not protect the assessee from Section 69A unless the source is satisfactorily explained with evidence. Since the AO conducted no independent inquiry about the nature and source of the undisclosed income, Explanation 2(a) to Section 263 applied. The assessee's appeals were dismissed. Case-Laws Income Tax Mon, 02 Jun 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=772285