2025 (4) TMI 152

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....R PER SATBEER SINGH GODARA, JM This assessee's appeal for assessment year 2013-14, arises against the Principal Commissioner of Income Tax (Central), Delhi's DIN and order no. ITBA/REV/F/REV5/2023-24/1063487836(1), dated 27.03.2024 involving proceedings under section 263 of the Income-tax Act, 1961 (hereinafter referred to as 'the Act'). 2. Heard both the parties. Case file perused. 3. We adve....

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....epting the additional income of Rs. 1,12,50,000/- including the above cash sum amounting to Rs. 70 lakhs which again has attained finality. 4. Both the parties next invite our attention to the PCIT's section 263 show-cause notice dated 21.02.2024 proposing to exercise his revisional jurisdiction (pages 62 to 65) on the issue of 2(22)(e) deemed dividend of Rs. 88,87,728/-, commission payment made ....