Exercise of revisionary jurisdiction u/s 263 by PCIT for substituting his opinion is untenable

Kusuma Cashews Vs PCIT (ITAT Bangalore) ITAT Bangalore held that revisionary jurisdiction under section 263 of the Income Tax Act could not be allowed to be exercised by the PCIT either for substituting his own opinion for that of the AO or for making a fishing and roving enquiry. Facts- During the course of survey, the officials noticed that as per the books of accounts maintained in the business premises, the stock of finished goods of cashew kernels was 5,389.80 kgs. and raw materials was 81,583 kgs. On physical verification, the officials found the finished goods of 5,021 kgs. And raw mate...