Revisionary proceedings u/s 263 exercised only based on facts verifiable from records is unjustified

Mukesh Kumar Agarwalla Vs PCIT (ITAT Kolkata) ITAT Kolkata held that exercising revisionary proceedings u/s. 263 of the Income Tax Act purely on facts which are verifiable from records of the assessee is not justifiable and hence liable to be quashed. Facts- The assessee is the owner of warehouses at Khanapara, Guwahati and has executed works contract during the period under consideration. Case of the assessee was selected for scrutiny. In the course of assessment, assessee appeared and furnished copy of tax audit report in Form No. 3CB and 3CD, bank statement, computation of total income, For...