https://www.taxtmi.com/caselaws?id=783114 ITAT Delhi allowed the assessee's appeal and quashed the PCIT's revisionary order u/s 263. The AO, in reassessment u/s 147, had already treated purchases from a specific supplier as bogus and disallowed them u/s 37(1). PCIT directed the AO to instead invoke s.69C and apply s.115BBE. ITAT held that s.69C applies only where there is unexplained expenditure or unsatisfactory explanation of its source. Since the AO had never doubted the source of funds but only the genuineness of purchases, s.69C was inapplicable. Consequently, the assessment was neither erroneous nor prejudicial to the Revenue, invalidating the s.263 revision. en-us Fri, 28 Nov 2025 00:00:00 +0530 Wed, 10 Dec 2025 08:41:43 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=783114 ITAT Delhi allowed the assessee's appeal and quashed the PCIT's revisionary order u/s 263. The AO, in reassessment u/s 147, had already treated purchases from a specific supplier as bogus and disallowed them u/s 37(1). PCIT directed the AO to instead invoke s.69C and apply s.115BBE. ITAT held that s.69C applies only where there is unexplained expenditure or unsatisfactory explanation of its source. Since the AO had never doubted the source of funds but only the genuineness of purchases, s.69C was inapplicable. Consequently, the assessment was neither erroneous nor prejudicial to the Revenue, invalidating the s.263 revision. Case-Laws Income Tax Fri, 28 Nov 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=783114