Revisional jurisdiction u/s 263 not invocable when AO takes one possible view: ITAT Delhi

Gulshan Kumar Vs PCIT (ITAT Delhi) ITAT Delhi held that PCIT cannot assume revisional jurisdiction under section 263 of the Income Tax Act when in case of debatable issue, out of the two possible views, AO accepts one of the views. Facts- The assessee is an individual who runs M/s. Gulshan Variety Store, Fatehabad. For the A.Y. 2018-19 he filed his return declaring income of Rs. 27,900/- on 01.02.2019. The case was selected for complete scrutiny. AO completed the assessment on 03.12.2020 u/s. 143(3) of the Act on total income of Rs. 27,900/- as returned by the assessee after taking into accoun...