Reopening on incorrect assumption of fact is invalid, hence subsequent revision order u/s 263 bad-in-law

Pantime Finance Company Pvt. Ltd. Vs ITO (ITAT Mumbai) ITAT Mumbai held that as entire reasons for reopening were recorded by incorrect assumption of facts, accordingly, reopening was invalid and bad-in-law. Hence, subsequent invocation of revisional jurisdictional under section 263 of the Income Tax Act is untenable in law. Facts- The only issue to be decided in this appeal is asked whether the learned PCIT was justified in invoking revisional jurisdiction under section 263 of the Act on facts as well as on law. The moot question to be decided in this appeal is as to whether the learned PCIT ...