PCIT cannot substitute AO’s view solely based on his interpretation of facts under Section 263: ITAT Rajkot

Vaidya Realities Vs PCIT (ITAT Rajkot)

Introduction: The ITAT Rajkot recently deliberated on the Vaidya Realities vs PCIT case, centering around the Section 263 review of the AO’s assessment under the Income Tax Act, 1961. The appellant, a partnership firm engaged in real estate, contested the PCIT’s characterization of the assessment under Section 143(3) as erroneous and prejudicial to revenue.

Detailed Analysis: The crux of the matter lies in

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