https://www.taxtmi.com/caselaws?id=784377 The dominant issue was whether the PCIT validly invoked revision jurisdiction under s.263 to direct additions under s.68 for unsecured loans. The Tribunal held that, in the s.263 giving-effect proceedings, the AO examined record evidence establishing identity, creditworthiness, and genuineness for 15 creditors and adopted a plausible view; therefore, the assessment was neither "erroneous" nor "prejudicial to the interests of the Revenue" within Malabar Industrial Co. Ltd and Max India Ltd, and s.263 revision on this aspect was quashed. As to three creditors, the impugned amount was only an interest-payable journal entry without any "sum of money" received during the year, so s.68 was inapplicable; the AO's view was plausible and revision was unsustainable. The assessee's appeal was allowed. en-us Wed, 31 Dec 2025 00:00:00 +0530 Sat, 03 Jan 2026 08:03:42 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=784377 The dominant issue was whether the PCIT validly invoked revision jurisdiction under s.263 to direct additions under s.68 for unsecured loans. The Tribunal held that, in the s.263 giving-effect proceedings, the AO examined record evidence establishing identity, creditworthiness, and genuineness for 15 creditors and adopted a plausible view; therefore, the assessment was neither "erroneous" nor "prejudicial to the interests of the Revenue" within Malabar Industrial Co. Ltd and Max India Ltd, and s.263 revision on this aspect was quashed. As to three creditors, the impugned amount was only an interest-payable journal entry without any "sum of money" received during the year, so s.68 was inapplicable; the AO's view was plausible and revision was unsustainable. The assessee's appeal was allowed. Case-Laws Income Tax Wed, 31 Dec 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=784377