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ITAT ruled against Principal CIT's revision under Section 263, finding the order procedurally flawed. The tribunal held that PCIT cannot delegate verification responsibilities to AO without independently establishing that the original assessment order was erroneous and prejudicial to revenue interests. PCIT failed to consider submitted documents and make necessary observations before concluding the order's erroneousness. The tribunal emphasized that outsourcing Section 263 jurisdiction to AO is legally impermissible, as it would implicitly vest revision powers with AO. Consequently, ITAT set aside PCIT's Section 263 order and restored AO's original assessment under Section 143(3), allowing the taxpayer's appeal.
ITAT ruled against Principal CIT's revision under Section 263, finding the order procedurally flawed. The tribunal held that PCIT cannot delegate verification responsibilities to AO without independently establishing that the original assessment order was erroneous and prejudicial to revenue interests. PCIT failed to consider submitted documents and make necessary observations before concluding the order's erroneousness. The tribunal emphasized that outsourcing Section 263 jurisdiction to AO is legally impermissible, as it would implicitly vest revision powers with AO. Consequently, ITAT set aside PCIT's Section 263 order and restored AO's original assessment under Section 143(3), allowing the taxpayer's appeal.
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