Section 263 Revision Unjustified Without Material Evidence: Kerala HC

PCIT Vs Ayyappa Roller Flour Mills Ltd (Kerala High Court) In a significant ruling, the Kerala High Court has dismissed an Income Tax Appeal filed by the Revenue, upholding the decision of the Income Tax Appellate Tribunal (ITAT), Cochin Bench. The court held that an assessment completed based on a Departmental Valuation Officer’s (DVO) report cannot be revised under Section 263 of the Income Tax Act, 1961, merely due to subsequent administrative doubts or a lack of concrete material demonstrating that the original assessment was erroneous and prejudicial to the Revenue’s interests...