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

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