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ITAT set aside the revisionary directions issued by the Pr. CIT under s.263 and allowed the assessee's appeal. The Tribunal held the AO's order, rendered after limited scrutiny to verify a large refund claim, was neither erroneous nor prejudicial to revenue; therefore the twin conditions for exercise of s.263 jurisdiction were not satisfied. The Pr. CIT's attempt to expand scrutiny by invoking Explanation 2 to s.263 was impermissible absent specific findings demonstrating any statutory condition in that Explanation was breached. The Pr. CIT failed to identify error of law or fact or want of verification by the AO; consequently the revision order was quashed and the s.263 direction set aside.
ITAT set aside the revisionary directions issued by the Pr. CIT under s.263 and allowed the assessee's appeal. The Tribunal held the AO's order, rendered after limited scrutiny to verify a large refund claim, was neither erroneous nor prejudicial to revenue; therefore the twin conditions for exercise of s.263 jurisdiction were not satisfied. The Pr. CIT's attempt to expand scrutiny by invoking Explanation 2 to s.263 was impermissible absent specific findings demonstrating any statutory condition in that Explanation was breached. The Pr. CIT failed to identify error of law or fact or want of verification by the AO; consequently the revision order was quashed and the s.263 direction set aside.
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