Section 263 Revision Upheld as AO Taxed Only TDS Credit Instead of Undisclosed Commission

Vikunj Real Estate Private Limited Vs ITO (ITAT Delhi) Wrong Tax Target Chosen: PCIT’s s.263 Action Upheld as AO Taxed Only TDS Credit Instead of Undisclosed Commission Delhi ITAT, Bench ‘C’, in Vikunj Real Estate Pvt. Ltd. vs. ITO (ITA No. 3179/Del/2025, AY 2011-12, order dated 22.12.2025), dismissed the Assessee’s appeal and upheld revisionary jurisdiction exercised by PCIT u/s 263. The case originated from reassessment u/s 147 based on Investigation Wing information that Assessee had received substantial commission income from BPTP Ltd., on which TDS was deducted. During reassessmen...