2025 (4) TMI 152

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..... ER PER SATBEER SINGH GODARA, JM This assessee's appeal for assessment year 2013-14, arises against the Principal Commissioner of Income Tax (Central), Delhi's DIN and order no. ITBA/REV/F/REV5/2023-24/1063487836(1), dated 27.03.2024 involving proceedings under section 263 of the Income-tax Act, 1961 (hereinafter referred to as 'the Act'). 2. Heard both the parties. Case file perused. 3. We adv .....

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..... cepting the additional income of Rs. 1,12,50,000/- including the above cash sum amounting to Rs. 70 lakhs which again has attained finality. 4. Both the parties next invite our attention to the PCIT's section 263 show-cause notice dated 21.02.2024 proposing to exercise his revisional jurisdiction (pages 62 to 65) on the issue of 2(22)(e) deemed dividend of Rs. 88,87,728/-, commission payment made .....

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..... Pvt. Ltd. (2023) 454 ITR 212. The Revenue could hardly pinpoint any specific seized material so far as the PCIT's impugned proposal pertaining to deemed dividend, commission payments and banking transactions (supra) is concerned. This being the clinching case, we are of the considered view that the impugned section 153A assessment framed in the assessee's case on 04.05.2021 could neither be termed .....

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