2025 (4) TMI 152

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....ment : Sh. Sunil Yadav, CIT(DR) ORDER 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 bot....

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....t incase of M/s. Tahiliani Design Pvt. Ltd. accepting 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 divi....

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....d material only as per PCIT Vs. Abhisar Buildwell Pvt. Ltd. (2023) 454 ITR 212. The Revenue could hardly pinpoint any specific seized material so far as the PCIT's impugned proposal pertaining to deemed dividend, commission payments and banking transactions (supra) is concerned. This being the clinching case, we are of the considered view that the impugned section 153A assessment framed in the ass....