Mechanical Invocation of Section 263 at AO’s Behest Held Bad in Law

Indian City Properties Limited Vs PCIT (ITAT Kolkata) The Tribunal held that the invocation of Section 263 on the proposal of the AO is not sustainable under the Act, as the PCIT failed to independently apply his mind and record satisfaction of the twin conditions. The assessment was completed under Section 143(3) r.w.s. 144B after verification of documents, and the returned income was consciously accepted by the Faceless Assessment Unit. Mere non-consideration of the DVO’s valuation report or a difference of opinion does not render the assessment erroneous and prejudicial to the interest of...