Section 263 Invocation Unjustified if No Evidence of Erroneous Order

Nirav Chandrakantbhai Bhalani Vs PCIT (ITAT Ahmedabad) ITAT Ahmedabad held that invocation of section 263 by PCIT unjustified due lack of sufficient evidence to support claim that the order is erroneous and prejudicial to the interest of revenue. Facts- The assessee is an individual. AO passed the order u/s. 147 r.w.s. 144 of the Act, accepting the return as declared by the assessee. Thereafter, PCIT issued a notice of hearing exercising his powers u/s.263 of the Act relating to assessment order passed by AO u/s 147 read with section 144 of the Act. In the said notice the PCIT stated the asses...