https://www.taxtmi.com/caselaws?id=449999 ITAT Jodhpur held that PCIT's revision u/s 263 was invalid where AO had already examined the issue and allowed deduction u/s 80P(2)(d) after proper inquiry. The tribunal ruled that revision cannot be used merely to review AO's opinion or impose a different view when AO adopted a permissible course in law. Following SC precedents in Malabar Industrial Co. Ltd and Max India, the tribunal emphasized that revenue loss alone doesn't justify revision unless the AO's view is totally unsustainable. Since assessment was conducted with due inquiry and verification, PCIT lacked power to invoke s.263. Assessee's appeal was allowed. en-us Tue, 20 Feb 2024 00:00:00 +0530 Sat, 24 Feb 2024 09:27:51 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=449999 ITAT Jodhpur held that PCIT's revision u/s 263 was invalid where AO had already examined the issue and allowed deduction u/s 80P(2)(d) after proper inquiry. The tribunal ruled that revision cannot be used merely to review AO's opinion or impose a different view when AO adopted a permissible course in law. Following SC precedents in Malabar Industrial Co. Ltd and Max India, the tribunal emphasized that revenue loss alone doesn't justify revision unless the AO's view is totally unsustainable. Since assessment was conducted with due inquiry and verification, PCIT lacked power to invoke s.263. Assessee's appeal was allowed. Case-Laws Income Tax Tue, 20 Feb 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=449999