https://www.taxtmi.com/caselaws?id=781587 ITAT allowed the assessee's appeal, holding the revision order under section 263 unsustainable because the PCIT lacked jurisdiction. The tribunal found the AO had made enquiries and accepted documentary evidence; mere passage of three years does not, by itself, establish that a trading liability ceased. Revenue must demonstrate the liability truly ceased or was written off. The PCIT's reliance on time alone was inadequate to invoke section 41(1) or section 263, so the revision was set aside and the assessment restored. en-us Mon, 27 Oct 2025 00:00:00 +0530 Tue, 18 Nov 2025 08:42:57 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=781587 ITAT allowed the assessee's appeal, holding the revision order under section 263 unsustainable because the PCIT lacked jurisdiction. The tribunal found the AO had made enquiries and accepted documentary evidence; mere passage of three years does not, by itself, establish that a trading liability ceased. Revenue must demonstrate the liability truly ceased or was written off. The PCIT's reliance on time alone was inadequate to invoke section 41(1) or section 263, so the revision was set aside and the assessment restored. Case-Laws Income Tax Mon, 27 Oct 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=781587