Invocation of revisional jurisdiction u/s 263 on mere conjectures, suspicions and surmises, is impermissible

Impact Foundation (India) Vs CIT (ITAT Mumbai) ITAT Mumbai held that initiated revision jurisdiction under section 263 of the Income Tax Act on mere conjectures, suspicions and surmises, is not permissible in law. Facts- The assessee is a non-profit company (charitable institution) and it is registered u/s 12AA of the Act. The assessment in the hands of the assessee for the year under consideration was completed by the AO u/s 143(3) of the Act on 12-12-2019 accepting ROI filed by the assessee. CIT(E), upon examination of assessment record, noticed that the assessee had claimed deduction toward...