https://www.taxtmi.com/caselaws?id=773896 ITAT Delhi held that PCIT's revision u/s 263 was invalid where assessment was completed u/s 153A treating unsecured loans as unexplained cash credits u/s 68. The tribunal found that since the principal loan amount was already disputed before CIT(A), the interest disallowance on alleged bogus loans fell within CIT(A)'s enhancement powers rather than constituting a new income source requiring revision proceedings. The tribunal quashed the revision order, ruling that PCIT wrongly invoked s 263 jurisdiction when the matter could have been addressed by CIT(A) through enhancement powers. Appeal decided in favor of assessee. en-us Fri, 27 Jun 2025 00:00:00 +0530 Mon, 30 Jun 2025 08:43:50 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=773896 ITAT Delhi held that PCIT's revision u/s 263 was invalid where assessment was completed u/s 153A treating unsecured loans as unexplained cash credits u/s 68. The tribunal found that since the principal loan amount was already disputed before CIT(A), the interest disallowance on alleged bogus loans fell within CIT(A)'s enhancement powers rather than constituting a new income source requiring revision proceedings. The tribunal quashed the revision order, ruling that PCIT wrongly invoked s 263 jurisdiction when the matter could have been addressed by CIT(A) through enhancement powers. Appeal decided in favor of assessee. Case-Laws Income Tax Fri, 27 Jun 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=773896