Section 263 cannot be invoked based on incorrect understanding / appreciation of facts

Kishorkumar Bhalara Vs PCIT (ITAT Rajkot) The case of Kishorkumar Bhalara Vs PCIT (ITAT Rajkot) revolves around the jurisdictional aspects of Section 263 of the Income Tax Act, 1961. The appellant, Kishorkumar Bhalara, contested the order passed by the Ld. Principal Commissioner of Income Tax (PCIT), Rajkot-1, which invoked Section 263 to revise the assessment for the Assessment Year 2016-17. Detailed Analysis The crux of the matter lay in the PCIT’s assertion that the assessment order passed under Section 143(3) of the Act was erroneous and prejudicial to the interest of revenue due to ...