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Section 263 Revision Upheld as AO Taxed Only TDS Credit Instead of Undisclosed Commission
Case Law Details
- Case Name
- Vikunj Real Estate Private Limited Vs ITO (ITAT Delhi)
- Appeal Number
- Only available for paid members
- Date of Judgement/Order
- Only available for paid members
- Related Assessment Year
- 2011-12
- Courts
- All ITAT, ITAT Delhi
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Vikunj Real Estate Private Limited Vs ITO (ITAT Delhi)
Wrong Tax Target Chosen: PCIT’s s.263 Action Upheld as AO Taxed Only TDS Credit Instead of Undisclosed Commission
Delhi ITAT, Bench ‘C’, in Vikunj Real Estate Pvt. Ltd. vs. ITO (ITA No. 3179/Del/2025, AY 2011-12, order dated 22.12.2025), dismissed the Assessee’s appeal and upheld revisionary jurisdiction exercised by PCIT u/s 263.
The case originated from reassessment u/s 147 based on Investigation Wing information that Assessee had received substantial commission income from BPTP Ltd., on which TDS was deducted. During reassessmen...


