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    <title>2025 (11) TMI 636 - ITAT DELHI</title>
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    <description>ITAT DELHI - AT set aside PCIT&#039;s revision under s.263 that had annulled an assessment under s.143(3). The tribunal found the show-cause related only to alleged failure to deduct TDS under s.195 and that the AO had examined evidence (agreements, remittances, bank records), made enquiries and allowed the claim. Because the twin conditions for s.263 (order is erroneous and prejudicial to revenue) were not satisfied and the CIT&#039;s direction to probe unrelated purchases/exports without giving opportunity was vitiated, the s.263 order was held bad in law and quashed.</description>
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    <pubDate>Wed, 24 Sep 2025 00:00:00 +0530</pubDate>
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      <title>2025 (11) TMI 636 - ITAT DELHI</title>
      <link>https://www.taxtmi.com/caselaws?id=781168</link>
      <description>ITAT DELHI - AT set aside PCIT&#039;s revision under s.263 that had annulled an assessment under s.143(3). The tribunal found the show-cause related only to alleged failure to deduct TDS under s.195 and that the AO had examined evidence (agreements, remittances, bank records), made enquiries and allowed the claim. Because the twin conditions for s.263 (order is erroneous and prejudicial to revenue) were not satisfied and the CIT&#039;s direction to probe unrelated purchases/exports without giving opportunity was vitiated, the s.263 order was held bad in law and quashed.</description>
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      <pubDate>Wed, 24 Sep 2025 00:00:00 +0530</pubDate>
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