Invoking jurisdiction u/s. 263 based on second view of PCIT not permissible: ITAT Ahmedabad

Adani Wilmar Limited Vs PCIT (ITAT Ahmedabad) ITAT Ahmedabad held that invocation of revisionary jurisdiction under section 263 of the Income Tax Act not justified as view taken by PCIT was second view and the same is not permissible u/s. 263. Facts- The return of income for AY 2018-19 was filed on 26.11.2018 declaring total income of Rs.7,29,10,574/-. Assessment order u/s.143(3) r.w.s 144B of the Income-tax Act, 1961 was passed on 07.06.2021 at the assessed income of Rs.569,46,59,915/-. The Assessing Officer has made addition of Rs.7,32,417/-on account of disallowance u/s.14A of the Act. The ...