PCIT Cannot invoke Section 263 to Change Profit Estimation Rate: ITAT Nagpur

Sanjay Umarshi Dand Vs PCIT (ITAT Nagpur) The case of Sanjay Umarshi Dand vs. PCIT before ITAT Nagpur revolved around the invocation of Section 263 of the Income Tax Act by the Principal Commissioner of Income Tax (PCIT). The Assessing Officer (AO) had initially reopened the assessment under Section 147 due to high-value transactions (₹2.16 crore) in the assessee’s ICICI Bank account. Since the assessee had not filed a return initially, notices under Sections 148 and 142(1) were issued. The AO estimated income at 2% of total bank credits under Section 144, leading to an assessed income of ...