Revision u/s. 263 set aside as based on assumption and presumption: ITAT Jaipur

Rajesh Choudhary Vs ACIT (ITAT Jaipur)

ITAT Jaipur held that invocation of revisionary proceedings u/s. 263 of the Income Tax Act not sustainable since AO duly verified investment and payment of ESI/PF. Accordingly, revision is merely on the basis of assumption and presumption and doesn’t indicate that order is prejudicial to the interest of revenue.

Facts- Post completion of assessment proceeding, PCIT called for the assessment records in accordance with the provision of section 263 of the Act. While examining the assessment record ld. PCIT observed that

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