Non-satisfaction of twin conditions doesn’t sustain revisionary jurisdiction u/s 263

Abhishek Sheti Udyog Bhandar Vs PCIT (ITAT Pune) ITAT Pune held that revisionary jurisdiction under section 263 of the Income Tax Act unjustified in absence of satisfying twin conditions which is mandatory preceded the invocation of revisionary jurisdiction. Facts- On the receipt of information that, assessee found to have made huge deposits of special bank note [SBN] into various bank accounts, the return of the assessee was subjected to scrutiny u/s 143(3) of the Act. After going through the written submission filed by assessee in response to notice u/s 142(1), the Ld. Asstt. Commissioner of...