Revision action u/s. 263 cannot be taken as AO has applied his mind

Sevugan Pethaperumal Vs PCIT (ITAT Chennai) ITAT Chennai held that invocation of revisionary proceedings under section 263 of the Income Tax Act not justified as AO has applied his mind and revision u/s. 263 cannot be possible for mere change of opinion. Accordingly, appeal allowed. Facts- Post completion of assessment and details enquiry by AO, PCIT invoked revisionary proceedings by issuing a show cause notice u/s 263. It was observed that the rental income disclosed by the assessee ought to have been taxed as income house property and was wrongly offered as income from other sources. Being ...