Conditions for invoking Section 263: AO Order must be Erroneous & Prejudicial to Revenue

CIT – International Taxation Vs Saif Partner India IV Ltd (Delhi High Court) Introduction: The Delhi High Court, in a recent judgment regarding CIT – International Taxation, emphasized the necessity of satisfying twin conditions under Section 263. The court deemed an order passed under this section invalid without fulfilling both requirements. Detailed Analysis: The case, identified as ITA 809/2023, pertains to the Assessment Year 2017-18. The appellant/revenue sought to challenge the Income Tax Appellate Tribunal’s order dated 13.02.2023, which had set aside the Commissioner...