Non-application of mind to legal issues justifies revisionary action u/s. 263

Buckeye Trust Vs PCIT-2 (ITAT Bangalore)

ITAT Bangalore held that non application of mind by the AO to the legal issues would justify action of section 263 of the Income Tax Act. Accordingly, appeal of the assessee dismissed and action of PCIT in holding order of AO as erroneous and prejudicial to interest of revenue justified.

Facts- Assessee is a private discretionary trust and was established under the provisions of Indian Trust Act, 1882 vide settlement deed dated January 23, 2018 executed between Mr. Anand Nadathur, being the Settlor and Vervain Managem

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