https://www.taxtmi.com/caselaws?id=783564 Revision under s.263 was examined on whether the assessment was erroneous and prejudicial in relation to alleged unexplained purchases/sales and profit computation. For purchases linked to sales already accepted in the seller's hands and concluded in first appeal, the Tribunal held the amount could not be treated as unexplained in the purchaser's hands and the PCIT could not direct the AO to undo the CIT(A)'s finding; revision was quashed to that extent. For purchases from another supplier whose sales were not shown to have been accepted (the supplier faced addition for bogus sales despite surrender), the AO's enquiry was held incomplete, justifying PCIT's direction for de novo assessment; revision was upheld on this issue. Non-explanation of differing net profit figures also supported de novo consideration, and audit-objection-based initiation was held valid. Appeal partly allowed. en-us Fri, 12 Dec 2025 00:00:00 +0530 Thu, 18 Dec 2025 08:01:59 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=783564 Revision under s.263 was examined on whether the assessment was erroneous and prejudicial in relation to alleged unexplained purchases/sales and profit computation. For purchases linked to sales already accepted in the seller's hands and concluded in first appeal, the Tribunal held the amount could not be treated as unexplained in the purchaser's hands and the PCIT could not direct the AO to undo the CIT(A)'s finding; revision was quashed to that extent. For purchases from another supplier whose sales were not shown to have been accepted (the supplier faced addition for bogus sales despite surrender), the AO's enquiry was held incomplete, justifying PCIT's direction for de novo assessment; revision was upheld on this issue. Non-explanation of differing net profit figures also supported de novo consideration, and audit-objection-based initiation was held valid. Appeal partly allowed. Case-Laws Income Tax Fri, 12 Dec 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=783564