https://www.taxtmi.com/caselaws?id=753544 ITAT Jaipur allowed the assessee's appeal against PCIT's revision order u/s 263 regarding addition u/s 68 for alleged bogus long-term capital gains through penny stock trading. The tribunal held that both conditions for invoking section 263 - order being erroneous and prejudicial to revenue - must be satisfied. Since AO had adopted a permissible view in law and PCIT merely disagreed without proving the view was totally unsustainable, the revision was invalid. The tribunal concluded it was merely a change of opinion by PCIT, which is not permitted under law, and vacated the section 263 order. en-us Mon, 03 Jun 2024 00:00:00 +0530 Wed, 05 Jun 2024 08:16:28 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=753544 ITAT Jaipur allowed the assessee's appeal against PCIT's revision order u/s 263 regarding addition u/s 68 for alleged bogus long-term capital gains through penny stock trading. The tribunal held that both conditions for invoking section 263 - order being erroneous and prejudicial to revenue - must be satisfied. Since AO had adopted a permissible view in law and PCIT merely disagreed without proving the view was totally unsustainable, the revision was invalid. The tribunal concluded it was merely a change of opinion by PCIT, which is not permitted under law, and vacated the section 263 order. Case-Laws Income Tax Mon, 03 Jun 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=753544