Change of opinion by AO by requesting CIT to exercise 263 Section jurisdiction is not permitted

Om Prakash Agarwal Vs PCIT (ITAT Jaipur)

ITAT held  that the prerequisite exercise of jurisdiction by the learned Principal CIT under section 263 of the Act is that the order of the AO is established to be erroneous in so far as it is prejudicial to the interest of the Revenue. The Principal CIT has to be satisfied of twin conditions, namely (i) the order of the AO sought to be revised is erroneous; and (ii) it is prejudicial to the interests of the Revenue. If any one of them is absent i.e., if the assessment order is not

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