ITAT Nagpur Quashes PCIT’s 263 Revision: Protective Addition Cannot Be Substituted

Gajanand Financial Consultancy Pvt. Ltd. Vs PCIT (Central) (ITAT Nagpur) Protective vs Substantive-  Nagpur ITAT Quashes PCIT’s 263 Order – Protective Addition Cannot Be Re-engineered- Detailed Enquiry by AO Saves Assessment – Tribunal Rejects 263 Revision Assessee filed appeal against the order of PCIT (Central) dated 05.03.2024 passed u/s 263 whereby assessment framed u/s 143(3) r.w.s. 147 was held erroneous & prejudicial to the interest of revenue. Assessee had originally filed return declaring a loss of ₹4,250. Pursuant to search in Tapadiya Group on 16.01.2019, AO reopened th...