PCIT Cannot Convert Bogus Purchase Disallowance into Section 69C Income via Revision u/s 263

Manoj Kumar Vs ITO (ITAT Delhi) The reassessment for AY 2018-19 treated purchases of ₹11.47 lakh from a suspected accommodation entry provider as bogus and disallowed them under section 37(1), since the transactions were found non-genuine though recorded in the books and paid through banking channels. Invoking section 263, the PCIT held the assessment to be erroneous and directed the AO to instead tax the amount as unexplained expenditure under section 69C and apply the higher tax rate under section 115BBE. The Tribunal held this revision to be without jurisdiction. It noted that section 69C...