Allotment Date Counts for Indexation – PCIT Can’t Expand Limited Scrutiny – 263 Revision Quashed

Pradeep Kumar Rochwani Vs Circle (Intl Tax) (ITAT Jaipur) Facts  Assessee, an NRI residing in Dubai, filed return for AY 2018-19 declaring income of ₹5.51 Cr including LTCG of ₹5.45 Cr. Case was selected for limited scrutiny to verify refund claim. AO, after calling for details (bank statements, purchase agreement, sale deed, TDS etc.), accepted the return & completed assessment u/s 143(3) on 15.04.2021. Later, CIT invoked revision u/s 263, alleging that AO wrongly allowed excess indexation benefit by reckoning acquisition from 2009 (allotment letter) instead of 2012 (agreement date),...