Arbitral use of revisionary powers u/s. 263 is unsustainable

Surjeet Singh Vs PCIT (ITAT Chandigarh) ITAT held that CIT Cannot exercise  Revisionary Powers under Section 263 of Income Tax Act arbitrarily without satisfying twin conditions necessary for exercising  of powers. Facts- The AO passed an order u/s 143(3) dated 19.05.2017 wherein addition was made in regard to a Long Term Capital Gain where certain discrepancy in sale proceeds of SCF sold was noticed by the Assessing Officer. This order is set aside by the ld. PCIT by an order u/s 263 dated 19.05.2017. Assessee is aggrieved. Conclusion- Hon’ble Supreme Court in the case of CIT vs. Max Indi...