https://www.taxtmi.com/caselaws?id=782733 ITAT Delhi upheld the PCIT's assumption of revisional jurisdiction under s.263 in respect of unexplained credits treated as bogus capital gains under s.68 r.w. s.115BBE. The Tribunal held that, where the issue of bogus capital gains is pending and undecided before the CIT(A), clause (c) of Explanation 1 to s.263(1) permits the PCIT to revise the assessment on that very point. The pendency of appeal does not bar the PCIT from exercising revisional powers when the issue remains to be adjudicated. Consequently, the assessee's challenge to the s.263 proceedings failed and the appeal was dismissed. en-us Mon, 10 Nov 2025 00:00:00 +0530 Wed, 03 Dec 2025 08:57:08 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=782733 ITAT Delhi upheld the PCIT's assumption of revisional jurisdiction under s.263 in respect of unexplained credits treated as bogus capital gains under s.68 r.w. s.115BBE. The Tribunal held that, where the issue of bogus capital gains is pending and undecided before the CIT(A), clause (c) of Explanation 1 to s.263(1) permits the PCIT to revise the assessment on that very point. The pendency of appeal does not bar the PCIT from exercising revisional powers when the issue remains to be adjudicated. Consequently, the assessee's challenge to the s.263 proceedings failed and the appeal was dismissed. Case-Laws Income Tax Mon, 10 Nov 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=782733