Section 263 Revision Quashed as Capital Gains Must Reflect Only Real Income

Prem Singh Raja Vs PCIT (ITAT Chandigarh)  The appeals concerned two revision orders passed under Section 263 of the Income Tax Act for Assessment Years 2015–16 and 2017–18. The assessee had entered into agreements to sell immovable properties to M/s Hemali Resorts Pvt. Ltd., which was authorised to assign its rights. The final sale deeds were executed in favour of M/s APG Intelli Homes Pvt. Ltd. In both years, the consideration stated in the registered sale deeds was higher than the amount received by the assessee. The difference was paid by the purchaser to Hemali Resorts under separate...