PCIT cannot exercise revisionary jurisdiction under section 263 on material not confronted to assessee 

The Chhattisgarh High Court recently delivered a significant ruling in ACIT Vs Sun and Sun Inframetric Pvt. Ltd., examining the revisionary jurisdiction of the Principal Commissioner of Income Tax (PCIT) under section 263 of the Income Tax Act. The central point of discussion was whether the PCIT can exercise its jurisdiction based on material not confronted to the assessee.

Analysis:

The court observed that Section 68, invoked by the PCIT, is applicable for sums credited in

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