PCIT Cannot Act on AO’s Proposal: ITAT Pune Quashes Section 263 Revision

Hotel Sai Siddhi Pvt. Ltd. Vs PCIT (ITAT Pune) PCIT Cannot Act on AO’s Proposal: ITAT Pune Quashes Section 263 Revision for Jurisdictional Defect The Pune Bench of the ITAT quashed the revision order passed under Section 263, holding that the Principal Commissioner lacked jurisdiction as the proceedings were initiated solely on the basis of a proposal sent by the Assessing Officer. In this case, the assessee’s reassessment was completed accepting the returned loss. Subsequently, the Assessing Officer sent a formal proposal to the PCIT recommending revision under Section 263. Acting on this...