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

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