PCIT cannot substitute his view in exercise of revisional jurisdiction u/s. 263

Prashasti Enterprise Vs PCIT (ITAT Mumbai) The short contention on behalf of the assessee is that no notional rent is offered to tax in respect of unsold flats lying vacant held as closing stock is in line with the decision of Mumbai Bench of the Tribunal in the case of Osho Developers Vs. ACIT (supra). Whereas, the PCIT has taken a contrary view following the decision of Hon’ble Delhi High Court in the case of CIT vs. Ansal Housing Finance & Leasing Company Ltd. (supra). We find that in the case of Osho Developers vs. ACIT (supra), the Mumbai Bench of the Tribunal concluded that the...