https://www.taxtmi.com/caselaws?id=757526 ITAT Chennai held that PCIT's revision u/s 263 was invalid as it failed to establish the twin conditions that the assessment order was both erroneous and prejudicial to revenue interest. PCIT did not analyze whether assessee received exempt income before disallowing u/s 14A expenses, and regarding capital loss on asset sale, the disallowance was properly disclosed in the return. PCIT must provide objective reasoning and material basis for revision, not merely subjective satisfaction. Without demonstrating specific errors or prejudice to revenue, PCIT lacked jurisdiction to invoke revisionary powers. Assessee's appeal was allowed. en-us Thu, 01 Aug 2024 00:00:00 +0530 Wed, 28 Aug 2024 09:06:41 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=757526 ITAT Chennai held that PCIT's revision u/s 263 was invalid as it failed to establish the twin conditions that the assessment order was both erroneous and prejudicial to revenue interest. PCIT did not analyze whether assessee received exempt income before disallowing u/s 14A expenses, and regarding capital loss on asset sale, the disallowance was properly disclosed in the return. PCIT must provide objective reasoning and material basis for revision, not merely subjective satisfaction. Without demonstrating specific errors or prejudice to revenue, PCIT lacked jurisdiction to invoke revisionary powers. Assessee's appeal was allowed. Case-Laws Income Tax Thu, 01 Aug 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=757526