PCIT Cannot invoke Section 263 jurisdiction Solely Based on Disagreement with AO’s Plausible View

Satbir Mahato Vs PCIT (ITAT Kolkata) The appellant, Satbir Mahato, contested the order of the Principal Commissioner of Income Tax -5 Kolkata (PCIT) under Section 263. The crux of the matter lay in the disagreement regarding the exercise of jurisdiction by the PCIT without fulfilling the prerequisites under Section 263. The PCIT’s contention stemmed from the significant cash deposits into the appellant’s bank accounts, triggering a re-assessment under Section 147. Despite the appellant’s assertion of innocence and lack of involvement in the transactions, the PCIT deemed the a...