https://www.taxtmi.com/caselaws?id=781583 ITAT allowed the appeal, quashing the PCIT's revision order under s.263 as void-ab-initio. The Tribunal held the AO had conducted proper inquiry under s.153C r.w.s. s.143(3), accepted documentary evidence showing the assessee's actual cost of acquisition of loose diamonds (Rs. 2,49,00,849) and that capital gains tax was paid accordingly. The s.68 enhancement and recomputation of cost by comparing diamond prices to gold were found to be conjectural; revision by PCIT amounted to a changed opinion without new supporting material and thus was beyond jurisdiction. en-us Fri, 26 Sep 2025 00:00:00 +0530 Sat, 15 Nov 2025 11:01:36 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=781583 ITAT allowed the appeal, quashing the PCIT's revision order under s.263 as void-ab-initio. The Tribunal held the AO had conducted proper inquiry under s.153C r.w.s. s.143(3), accepted documentary evidence showing the assessee's actual cost of acquisition of loose diamonds (Rs. 2,49,00,849) and that capital gains tax was paid accordingly. The s.68 enhancement and recomputation of cost by comparing diamond prices to gold were found to be conjectural; revision by PCIT amounted to a changed opinion without new supporting material and thus was beyond jurisdiction. Case-Laws Income Tax Fri, 26 Sep 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=781583