263 Has Limits: Second Bite at Cherry Denied to Revenue

Decent Securities Private Limited Vs PCIT (ITAT Delhi) Delhi ITAT quashed second revision order passed u/s 263 holding that Pr. CIT exceeded jurisdiction by re-revising a plausible assessment view already taken by AO. In M/s. Decent Securities (P) Ltd vs. Pr. CIT, ITA No. 4799/Del/2025, AY 2017-18, Tribunal noted that original assessment u/s 143(3) dated 31.12.2019 had examined unsecured loans u/s 68. Though first revision u/s 263 dated 11.03.2022 was passed when appeal against assessment was already pending before CIT(A), AO thereafter passed fresh order u/s 143(3) r.w.s. 263 on 30.03.2023. P...