PCIT Cannot Invoke Section 263 for Mere Technical Lapse

Smt. Suchita Goyal Vs PCIT (ITAT Delhi) Mere Change of Opinion Not Enough: Delhi ITAT Quashes s.263 Revision on Interest Deduction u/s 24(b) Delhi ITAT set aside the revisionary order passed u/s 263, holding that the assessment order allowing deduction of interest on borrowed capital u/s 24(b) was neither erroneous nor prejudicial to the interests of the Revenue. The PCIT had invoked s.263 on the ground that the AO wrongly allowed interest deduction of ₹96.01 lakh on borrowed capital for house property, alleging absence of an interest certificate from the lender and lack of nexus between the...