Section 263 Checkmated – ITAT Says PCIT Cannot Reopen Issues Already Before CIT(A)

Vaksons Metaplast Pvt Ltd Vs PCIT (Central) (ITAT Delhi) Tribunal examined revision u/s 263 against an assessment u/s 153C arising from incriminating material found in search of Sumit Jindal group. Director of Assessee admitted during survey u/s 133A/132(4) that purchases & sales from Jindal’s entities were bogus & only 0.50% commission was earned. AO, after detailed enquiry, taxed only 0.50% commission u/s 69C. Assessee filed appeal before CIT(A) challenging the same. PCIT thereafter issued notice u/s 263 holding that entire bogus purchase of Rs.1,59,96,530 should have been added u/...