Invocation of section 263 not possible on mere difference of opinion

APC Books Vs A.C.I.T (ITAT Delhi) Facts- The assessee has challenged the assumption of jurisdiction by the PCIT-10, Delhi u/s 263 of the Income-tax Act, 1961 wherein the PCIT has held that the assessment order dated 14.12.2019 framed u/s 143(3) of the Act is erroneous and prejudicial to the interest of the Revenue. The assessee stated that the Assessing Officer, during the course of assessment proceedings u/s 143(3) of the Act, has raised specific queries relating to the cash deposit after demonetization and has made detailed enquiries, for which the assessee has submitted a detailed reply alo...