https://www.taxtmi.com/caselaws?id=781512 ITAT held the assessment framed u/s 147 was erroneous and prejudicial to Revenue for failing to verify the source of Rs.20 lakh credited as past savings; the PCIT's invocation of revision u/s 263 was justified because the AO did not examine whether the account belonged to the assessee or how funds accumulated. The Tribunal noted Explanation 2 (w.e.f. 01.06.2015) changed the law and that accepting the assessee's unsupported contention was not a tenable view. Appeal by the assessee was dismissed. en-us Mon, 15 Sep 2025 00:00:00 +0530 Mon, 17 Nov 2025 08:36:47 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=781512 ITAT held the assessment framed u/s 147 was erroneous and prejudicial to Revenue for failing to verify the source of Rs.20 lakh credited as past savings; the PCIT's invocation of revision u/s 263 was justified because the AO did not examine whether the account belonged to the assessee or how funds accumulated. The Tribunal noted Explanation 2 (w.e.f. 01.06.2015) changed the law and that accepting the assessee's unsupported contention was not a tenable view. Appeal by the assessee was dismissed. Case-Laws Income Tax Mon, 15 Sep 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=781512