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of The Appellate Tribunal addressed the validity of a revision u/s 263, focusing on the alleged non-consideration of the assessee's submissions by the Principal Commissioner of Income Tax (PCIT). The PCIT's order was examined to determine if it aligned with the Tribunal's directive. The Tribunal found that the PCIT provided adequate opportunities for the appellant/assessee to be heard but these opportunities were not utilized. The PCIT was not required to reassess the original order but to act in accordance with the Tribunal's instructions. The Tribunal suggested that the PCIT should have considered one of the tables as reliable for expenditure allocation and encouraged resolving disputes with original documentation. Ultimately, the Tribunal set aside the PCIT's order, directing a fresh review of the computational error, emphasizing the importance of granting the appellant/assessee a fair opportunity to address any deficiencies without expressing a view on the case's merits.
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