Unjustified Invocation of Revisionary Power of Section 263 When AO’s Conclusion Is Reasonable

Ellora Infratech Pvt. Ltd. Vs PCIT (ITAT Delhi) ITAT Delhi held that invocation of revisionary power u/s. 263 of the Income Tax Act unjustified when AO has exercised its quasi-judicial powers and arrived at a conclusion with reasonable application of mind. Facts- The case of the assessee was assessed u/s. 143(3) of the Act. Subsequent to the assessment, the Pr. CIT received a proposal from the new incumbent AO vide its communication seeking invocation of supervisory jurisdiction u/s. 263 of the Act. Thereafter, in exercise of powers conferred u/s. 263 of the Act, the Pr. CIT issued SCN allegin...