Section 263 Invalid as PCIT Acted on AO’s Reference Without Independent Review: Calcutta HC

PCIT 1 Vs Britannia Industries Limited (Calcutta High Court) The appeal filed by the Revenue under Section 260A of the Income Tax Act, 1961 challenged the order of the Income Tax Appellate Tribunal (ITAT) dated March 6, 2024 for Assessment Year 2018–19. The Tribunal had allowed the assessee’s appeal and set aside the revisionary order passed by the Principal Commissioner of Income Tax (PCIT) under Section 263 of the Act. The Revenue raised multiple substantial questions of law relating to the validity of invoking Section 263, applicability of Section 56(2)(x) on property acquisition, and d...