Failure to Follow 263 Directions Renders Assessment Unsustainable

DCIT Vs Ankur Mittal (ITAT Delhi) AO can’t travel beyond 263 directions: ITAT Delhi upholds deletion of ₹12.12 cr u/s 69C; sustains ₹1.16 lakh u/s 69A Delhi Tribunal dismissed both the Revenue’s appeal and the assessee’s cross-objection. The Tribunal held that while giving effect to a revision u/s 263, the AO must strictly confine himself to the specific directions issued by the PCIT. In the present case, the PCIT had only directed examination of the applicability of section 40A(3) r/w Rule 6DD and related verifications. However, the AO travelled beyond the mandate and made a massive...