Naveen Narang v. Pr. CIT (2025) 132 ITR 759 (Delhi) (Trib.)

S. 263: Commissioner-Revision of orders prejudicial to revenue-Search and seizure-Seized documents showing unaccounted loan/investment transactions with repayments through billing account and large cash payments-Assessment made without proper enquiry-Assessing Officer taxing only commission instead of undisclosed income-Revision upheld. [S. 68, 69, 69A, 132, 153A]

Following search action revealing unaccounted loan and investment transactions between the assessee and another party, AO made additions under sections 68, 69 and 69A in the section 153A assessment, but the PCIT revised the order under section 263 holding it erroneous and prejudicial to the Revenue. On appeal, the Tribunal held that despite seized documents showing repayments through the billing account and substantial cash payments, AO had taxed only the commission on bogus billing instead of the entire undisclosed income, rendering the assessment erroneous and prejudicial to the Revenue, and upheld the revision. (AY. 2016-17)

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