https://www.taxtmi.com/caselaws?id=467066 The dispute addressed whether the Principal Commissioner validly exercised revisionary jurisdiction under section 263 to quash an AO's reassessment for alleged bogus purchases while the same issue was under appeal. The tribunal found the AO had made inquiries, considered survey reports, bank statements and transaction details, and the Commissioner (Appeals) had subsequently considered and endorsed the core issue, engaging the doctrine of merger (Explanation 1(c)) to preclude section 263 intervention. Explanation 2 was held inapplicable because the reassessment showed application of mind and verification. Result: the PCIT's revision order was quashed and the AO's reassessment order restored in favour of the assessee. en-us Fri, 21 Feb 2025 00:00:00 +0530 Wed, 04 Mar 2026 17:18:17 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=467066 The dispute addressed whether the Principal Commissioner validly exercised revisionary jurisdiction under section 263 to quash an AO's reassessment for alleged bogus purchases while the same issue was under appeal. The tribunal found the AO had made inquiries, considered survey reports, bank statements and transaction details, and the Commissioner (Appeals) had subsequently considered and endorsed the core issue, engaging the doctrine of merger (Explanation 1(c)) to preclude section 263 intervention. Explanation 2 was held inapplicable because the reassessment showed application of mind and verification. Result: the PCIT's revision order was quashed and the AO's reassessment order restored in favour of the assessee. Case-Laws Income Tax Fri, 21 Feb 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=467066