Section 263 Revision Quashed for Mechanical MAT Adjustment Without Fresh Error

Antony Lara Enviro Solutions Pvt. Ltd Vs PCIT (ITAT Mumbai)

This appeal before the Income Tax Appellate Tribunal, Mumbai concerned the validity of a revisionary order passed under section 263 of the Income-tax Act, 1961, for the assessment year 2020–21. The assessee challenged the jurisdiction assumed by the Principal Commissioner of Income-tax (PCIT), contending that the revision was based merely on a change of opinion and not on any real error in the assessment order.

The assessment for the year was completed under section 143(3) on 09.09.2022, wherein t

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