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ITAT allowed the appeal and set aside the PCIT's revisionary order under section 263. The Tribunal held that jurisdiction under section 263 requires both a demonstrable error in the AO's order and that the order be prejudicial to Revenue; absent either, revision cannot be validly exercised. PCIT conceded there was no error in the assessment concerning the assessee's claim of deduction under section 80G read with section 115BAA, and the AO had reached a plausible, lawful view after considering the assessee's submissions. Consequently, no error or prejudice was established and the impugned section 263 order was unsustainable in law.
ITAT allowed the appeal and set aside the PCIT's revisionary order under section 263. The Tribunal held that jurisdiction under section 263 requires both a demonstrable error in the AO's order and that the order be prejudicial to Revenue; absent either, revision cannot be validly exercised. PCIT conceded there was no error in the assessment concerning the assessee's claim of deduction under section 80G read with section 115BAA, and the AO had reached a plausible, lawful view after considering the assessee's submissions. Consequently, no error or prejudice was established and the impugned section 263 order was unsustainable in law.
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