Section 263 Revision not permissible on debatable issues

Orissa Forest Development Corporation Limited Vs PCIT (ITAT Cuttack) It is admitted by Pr. CIT that he is not going into the merits of the addition as the issue constitute a matter to be adjudicated by the appellate authority. Thus, it is clearly shows that the issue is a debatable issue and it is recognized by the Pr. CIT. On a debatable issue, admittedly, revision u/s.263 of the Act is not permissible. This being so, as the issue, as proposed by the pr. CIT, is a debatable issue, and as admitted by Pr. CIT in the impugned order, the order passed u/s.263 stands quashed. FULL TEXT OF THE ORDER...