The HC upheld the Tribunal's decision allowing the assessee's...

The HC upheld the Tribunal's decision allowing the assessee's appeal and setting aside the PCIT's order passed under Section 263. The PCIT wrongly invoked revisionary jurisdiction solely on the AO's reference without independently applying its mind. The valuation of leasehold land and building was upheld as fair, based on a registered valuer's report and disclosed facts, negating applicability of Section 56(2)(x) since the property acquisition predated the provision's insertion. The PCIT's factual errors regarding the AO's consideration of these aspects amounted to non-application of mind. Additionally, the PCIT failed to address the assessee's contention under Section 43B that reversal of provisions previously disallowed as expenses cannot be taxed again, necessitating remand for AO to examine relevant precedents with opportunity to the assessee. The HC confirmed the Tribunal's conclusion that the PCIT's order was unsustainable, ruling in favor of the assessee and against the revenue.