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ITAT held that the PCIT erroneously assumed jurisdiction under Section 263, as the Assessing Officer (AO) had conducted a thorough examination of the capital gains cost items and assessment. The faceless assessment process involved multiple units ensuring meticulous verification and review. The AO had called for explanations, examined submitted documents, and passed the order after careful consideration. Since the AO adopted a possible view on the interest cost claim and no error was conclusively established, the revision proceedings were deemed unsustainable. The tribunal found that the PCIT cannot initiate revision proceedings to conduct fishing or roving enquiries on matters already examined by the AO. Consequently, the appeal of the assessee was allowed, setting aside the PCIT's revision order.
ITAT held that the PCIT erroneously assumed jurisdiction under Section 263, as the Assessing Officer (AO) had conducted a thorough examination of the capital gains cost items and assessment. The faceless assessment process involved multiple units ensuring meticulous verification and review. The AO had called for explanations, examined submitted documents, and passed the order after careful consideration. Since the AO adopted a possible view on the interest cost claim and no error was conclusively established, the revision proceedings were deemed unsustainable. The tribunal found that the PCIT cannot initiate revision proceedings to conduct fishing or roving enquiries on matters already examined by the AO. Consequently, the appeal of the assessee was allowed, setting aside the PCIT's revision order.
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