PCIT expressing different view by invoking section 263 not justified: ITAT Ahmedabad

Anil Exports (India) Vs DCIT (ITAT Ahmedabad)

ITAT Ahmedabad held that invocation of section 263 of the Income Tax Act not justifiable since PCIT expressed different view and the same amounts to second opinion. Thus, order passed u/s. 263 of the Act not justifiable.

Facts- The assessment order u/s. 143(3) of the Act was passed on 03-07-2015 determining total income of Rs. 11,70,590/-. Thereafter, reassessment proceedings initiated and order u/s. 147 r.w.s. 144B was passed on 28-03­2022 by accepting the returned income. Pr. CIT observed that the reasons for

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