Tax Commissioner's Revision Powers Upheld in Section 263 Case Over Undisclosed Property Sales and Capital Gains.

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....ITAT upheld revision proceedings u/s 263 regarding undisclosed property transactions discovered during recovery proceedings. The assessee had failed to report capital gains from three properties and subsequently acknowledged these transactions. Though initially captioned as a proposal u/s 263, the AO's information was deemed valid grounds for PCIT's intervention. The jurisdictional challenge regarding PCIT-21 versus PCIT-12's authority was rejected, as current jurisdiction lay with PCIT-12 when proceedings were initiated on 22.02.2021. The assessee's prior agreement to settle and subsequent failure to provide documentation within the stipulated timeframe further supported PCIT's findings. Appeal dismissed.....