Action of AO based on High Court decision not erroneous hence jurisdiction u/s. 263 unjustified

Heylands Exports Pvt. Ltd. Vs PCIT (ITAT Chennai)

ITAT Chennai held that action of AO based on jurisdictional High Court decision as prevalent on the specified time, which was later on reversed by the Supreme Court, cannot be held to be erroneous and prejudicial to the interest of revenue. Thus, invocation of jurisdiction u/s. 263 unjustified.

Facts- The case of the assessee was selected for scrutiny and the assessment completed u/s.143(3) read with section 144B of the Act on 22.04.2021 by the Faceless Assessment Unit/AO determining the assessed loss at Rs.1

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