Revisionary action u/s. 263 based on factual misconception bad-in-law

Rochem Separation Systems India Private Limited Vs PCIT (ITAT Mumbai) ITAT Mumbai held that exercising revisionary jurisdiction under section 263 of the Income Tax Act by PCIT on the basis of factual misconception is liable to be quashed. Accordingly, appeal allowed and order u/s. 263 quashed. Facts- The assessee, a resident corporate entity, is stated to be engaged in the business of manufacturing and trading of Water treatment systems, Water pollution control equipment and Bio filters and resource recovery systems. A.O. completed the assessment u/s. 143(3) of the Act vide order dated 15.04.2...