PCIT Cannot Recast Business Disallowance as Unexplained Expenditure Under Section 69C

Nabeel Construction Pvt. Ltd. Vs PCIT (ITAT Mumbai) The Income Tax Appellate Tribunal (ITAT) Mumbai heard an appeal filed by Nabeel Construction Pvt. Ltd. against an order dated March 27, 2025, passed by the Principal Commissioner of Income Tax (PCIT), Thane-1, under Section 263 of the Income-tax Act, 1961, for Assessment Year 2021-22. The assessee, engaged in construction as a sub-contractor, had filed a return declaring an income of ₹ 1,28,91,690/-. During scrutiny, the Assessing Officer (AO) noted purchases of ₹ 39,06,42,323/- against contract receipts of ₹ 42,16,53,285/-. Although th...