Difference of Opinion Not Enough to Invoke Revisionary Jurisdiction: ITAT Mumbai

Mridul Shashikant Khandelwal Vs PCIT (ITAT Mumbai) Section 263 Revision Quashed for Lack of Specific Defects in Assessment; PCIT Cannot Order Fresh Assessment After Adequate Enquiry by AO; Assessment Approved Under Section 153D Not Erroneous Without Clear Findings; Roving and Fishing Enquiries Not Permitted Under Section 263; Vague Allegations of Inadequate Enquiry Fail Section 263 Test The Mumbai Bench of the Income Tax Appellate Tribunal decided two connected appeals for Assessment Years 2018–19 and 2020–21, challenging revisionary orders passed by the Principal Commissioner of Income Ta...