Different opinion, not gives jurisdiction to exercise revisional power u/s 263

Rattan Singh Vs PCIT (ITAT Delhi)

It can be observed that revenue cannot disputed the fact that while making assessment specific queries were raised by the ld AO questioning the deposit of amounts in the bank account and taking rescue of section 44AD the assessee had sought immunity of explanation and offered income to be tax @8%, u/s 44AD. The office note referred by ld AR explicitly determines the issue in favour of the assessee. However, ld Revisional Authority has gone into the questions of facts about the source of the

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