https://www.taxtmi.com/caselaws?id=798670 Revisionary jurisdiction under Section 263 is confined, where an assessment is under appeal, to matters not considered and decided in that appeal. Revision of a bogus-purchase addition was therefore impermissible because its validity was already pending before the CIT(A). An assessment order cannot be treated as erroneous and prejudicial to Revenue merely because the PCIT prefers a different view where the Assessing Officer has adopted a legally permissible view on a debatable issue. Directions to invoke Section 69C and apply the consequential special tax rate under Section 115BBE were also unsustainable where the expenditure, source, banking payments and accounting entries had been explained. en-us Fri, 21 Aug 2026 00:00:00 +0530 Thu, 10 Sep 2026 08:51:23 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=798670 Revisionary jurisdiction under Section 263 is confined, where an assessment is under appeal, to matters not considered and decided in that appeal. Revision of a bogus-purchase addition was therefore impermissible because its validity was already pending before the CIT(A). An assessment order cannot be treated as erroneous and prejudicial to Revenue merely because the PCIT prefers a different view where the Assessing Officer has adopted a legally permissible view on a debatable issue. Directions to invoke Section 69C and apply the consequential special tax rate under Section 115BBE were also unsustainable where the expenditure, source, banking payments and accounting entries had been explained. Case-Laws Income Tax Fri, 21 Aug 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=798670