Invoking section 263 in guise of difference of opinion not justifiable: ITAT Mumbai

Ganesh Srinivasan Vs PCIT (ITAT Mumbai) ITAT Mumbai held that invocation of revisionary jurisdiction under section 263 of the Income Tax Act on account of difference of opinion is not sustainable in law. Accordingly, revision order passed by PCIT is liable to be quashed. Facts- The assessee is a Senior Counsel practicing before the Hon’ble Supreme Court of India. For the relevant assessment year, the assessment was completed u/s. 143(3) of the Act, wherein the Ld. AO accepted the returned income and also accepted the reconciliation of the difference between the income reported in Form 26AS a...