Change of Opinion Barred: Section 263 Invalid After Comprehensive AO Enquiry

Arunaben Kishorkumar Mandali Vs PCIT (ITAT Ahmedabad) PCIT Cannot Invoke Section 263 on Change of Opinion: ITAT Ahmedabad Quashes Revision Where AO Conducted Detailed Enquiry in 153C Assessment The Ahmedabad Bench of the ITAT allowed the assessee’s appeals for AYs 2017-18, 2018-19 and 2020-21 and quashed the revisionary orders passed by the PCIT under section 263. The Tribunal held that the foundational twin conditions for invoking section 263—namely that the assessment order must be erroneous and prejudicial to the interests of the Revenue—were not satisfied in the present case. The ass...