https://www.taxtmi.com/caselaws?id=783133 ITAT Delhi set aside the PCIT's revision u/s 263 on addition of alleged bogus purchases in a 153C assessment, holding that issues already raised in appeal before CIT(A) fall outside the permissible scope of revision under Explanation 1(c) to s.263. Since the subject matter of revision was identical to the matter pending before CIT(A), the order of AO could not be treated as "erroneous and prejudicial" for that purpose, rendering the s.263 assumption of jurisdiction invalid and liable to be quashed. As regards the new issue of non-levy of interest u/s 234A, the Tribunal stayed the PCIT's proceedings, and the assessee's appeal was partly allowed. en-us Fri, 05 Dec 2025 00:00:00 +0530 Mon, 08 Dec 2025 17:57:06 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=783133 ITAT Delhi set aside the PCIT's revision u/s 263 on addition of alleged bogus purchases in a 153C assessment, holding that issues already raised in appeal before CIT(A) fall outside the permissible scope of revision under Explanation 1(c) to s.263. Since the subject matter of revision was identical to the matter pending before CIT(A), the order of AO could not be treated as "erroneous and prejudicial" for that purpose, rendering the s.263 assumption of jurisdiction invalid and liable to be quashed. As regards the new issue of non-levy of interest u/s 234A, the Tribunal stayed the PCIT's proceedings, and the assessee's appeal was partly allowed. Case-Laws Income Tax Fri, 05 Dec 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=783133