https://www.taxtmi.com/caselaws?id=780006 ITAT AGRA held that the PCIT's revision under s.263 was unsustainable and quashed it, allowing the assessee's appeals. The Tribunal accepted the assessee's reliance on precedents that Circular No.8/2018 and the Finance Act, 2018 amendment to s.50C (and pari materia s.56(2)(vii)) apply retrospectively, so where FMV exceeds actual consideration by less than 10% the difference is ignored. The AO's acceptance of the returned income was justified; the PCIT's action amounted to a mere change of opinion without supporting judicial authority. en-us Mon, 13 Oct 2025 00:00:00 +0530 Thu, 16 Oct 2025 08:31:22 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=780006 ITAT AGRA held that the PCIT's revision under s.263 was unsustainable and quashed it, allowing the assessee's appeals. The Tribunal accepted the assessee's reliance on precedents that Circular No.8/2018 and the Finance Act, 2018 amendment to s.50C (and pari materia s.56(2)(vii)) apply retrospectively, so where FMV exceeds actual consideration by less than 10% the difference is ignored. The AO's acceptance of the returned income was justified; the PCIT's action amounted to a mere change of opinion without supporting judicial authority. Case-Laws Income Tax Mon, 13 Oct 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=780006