https://www.taxtmi.com/caselaws?id=784476 The dominant issue was whether the PCIT could assume revisionary jurisdiction under s.263 to recharacterize transactions, earlier accepted by the AO for estimating commission at 0.5%, as unexplained cash credits under s.68, when the same matter was already before the CIT(A). Applying Expln.1(c) to s.263(1), the ITAT held that once an issue is the subject matter of appeal, the statutory bar precludes s.263 revision on that issue; this view was consistent with HC precedents on the "larger issue" being pending in appeal. Consequently, the PCIT lacked jurisdiction and the impugned s.263 order was quashed, granting relief to the assessee. en-us Fri, 21 Nov 2025 00:00:00 +0530 Tue, 06 Jan 2026 08:47:37 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=784476 The dominant issue was whether the PCIT could assume revisionary jurisdiction under s.263 to recharacterize transactions, earlier accepted by the AO for estimating commission at 0.5%, as unexplained cash credits under s.68, when the same matter was already before the CIT(A). Applying Expln.1(c) to s.263(1), the ITAT held that once an issue is the subject matter of appeal, the statutory bar precludes s.263 revision on that issue; this view was consistent with HC precedents on the "larger issue" being pending in appeal. Consequently, the PCIT lacked jurisdiction and the impugned s.263 order was quashed, granting relief to the assessee. Case-Laws Income Tax Fri, 21 Nov 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=784476