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The Appellate Tribunal considered a case involving a revision u/s 263 due to discrepancies in the assessment order, including undisclosed TDS, differences in purchases in ITR, and incorrect deductions leading to under-assessment. The Tribunal referenced a previous case where it was established that the Principal Commissioner of Income Tax (PCIT) did not independently exercise jurisdiction u/s 263 but acted on the AO's proposal. The Tribunal noted that in this case, the AO also based the proposal on audit report objections. The Tribunal found that the PCIT did not apply an independent mind, as the notice u/s 263 mirrored the AO's proposal and audit report. Consequently, the Tribunal set aside the order u/s 263, ruling in favor of the assessee.
The Appellate Tribunal considered a case involving a revision u/s 263 due to discrepancies in the assessment order, including undisclosed TDS, differences in purchases in ITR, and incorrect deductions leading to under-assessment. The Tribunal referenced a previous case where it was established that the Principal Commissioner of Income Tax (PCIT) did not independently exercise jurisdiction u/s 263 but acted on the AO's proposal. The Tribunal noted that in this case, the AO also based the proposal on audit report objections. The Tribunal found that the PCIT did not apply an independent mind, as the notice u/s 263 mirrored the AO's proposal and audit report. Consequently, the Tribunal set aside the order u/s 263, ruling in favor of the assessee.
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