https://www.taxtmi.com/caselaws?id=449185 ITAT Jodhpur quashed PCIT's revision order u/s 263. The assessee's case was reopened based on third-party information, and AO completed assessment after recording reasons. PCIT invoked section 263 on the same issues, directing further verification of share transactions and broker ledger accounts. ITAT held that AO had already applied his mind, examined assessee's explanations with supporting evidence, and completed assessment. PCIT failed to demonstrate how the order was erroneous and prejudicial to revenue, merely seeking to conduct inquiries that could have been done during original assessment. The revision order was deemed invalid as it constituted impermissible change of opinion rather than correction of legal error. en-us Fri, 02 Feb 2024 00:00:00 +0530 Wed, 07 Feb 2024 11:32:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=449185 ITAT Jodhpur quashed PCIT's revision order u/s 263. The assessee's case was reopened based on third-party information, and AO completed assessment after recording reasons. PCIT invoked section 263 on the same issues, directing further verification of share transactions and broker ledger accounts. ITAT held that AO had already applied his mind, examined assessee's explanations with supporting evidence, and completed assessment. PCIT failed to demonstrate how the order was erroneous and prejudicial to revenue, merely seeking to conduct inquiries that could have been done during original assessment. The revision order was deemed invalid as it constituted impermissible change of opinion rather than correction of legal error. Case-Laws Income Tax Fri, 02 Feb 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=449185