ITAT Rejects Revision Since Issue Was Debatable and AO’s View Was Plausible

Bhavana Co-op. Credit Society Niyamita Vs PCIT (ITAT Bangalore) The Tribunal examined the scope of its jurisdiction in an appeal against a revision order passed under section 263 of the Income Tax Act. It reiterated that unlike a regular appeal against an assessment—where additions and disallowances are examined on facts and law—an appeal against a revision order is limited to assessing (1) whether the assumption of jurisdiction under section 263 is valid, (2) whether the Principal Commissioner’s (PCIT) conclusion that the order is “erroneous and prejudicial” is sustainable, and (3) ...