Section 263: ITAT explains five steps “Queen Principle”

Akola Janta Commercial Co-Op Bank Ltd. Vs ACIT (ITAT Nagpur)

A plain reading of Section 263 makes it clear that, the precondition to exercise revisionary jurisdiction by the PCIT/CIT suo moto under it, is that the order of AO is erroneous insofar as it is prejudicial to the interests of the revenue is concern. Consequently, the provision mandates the satisfaction of existence of twofold conditions before invocationand these explicitly are; (i) the order of the assessing officer sought to be revised is erroneous; and

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