https://www.taxtmi.com/caselaws?id=761909 ITAT Kolkata allowed assessee's appeal against PCIT's revision order u/s 263. PCIT had cancelled assessment framed u/s 147 r.w.s. 144, directing AO to reassess after verifying alleged bogus loans of Rs. 3,13,000 from four parties. ITAT held that assessment was neither erroneous nor prejudicial to revenue interest as these loan items didn't come to AO's notice during original proceedings. Relying on Malabar Industries Limited SC judgment, ITAT ruled that both conditions - erroneous and prejudicial - must be satisfied to invoke s. 263 jurisdiction, making PCIT's exercise of jurisdiction bad in law. en-us Mon, 18 Nov 2024 00:00:00 +0530 Wed, 20 Nov 2024 08:47:11 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=761909 ITAT Kolkata allowed assessee's appeal against PCIT's revision order u/s 263. PCIT had cancelled assessment framed u/s 147 r.w.s. 144, directing AO to reassess after verifying alleged bogus loans of Rs. 3,13,000 from four parties. ITAT held that assessment was neither erroneous nor prejudicial to revenue interest as these loan items didn't come to AO's notice during original proceedings. Relying on Malabar Industries Limited SC judgment, ITAT ruled that both conditions - erroneous and prejudicial - must be satisfied to invoke s. 263 jurisdiction, making PCIT's exercise of jurisdiction bad in law. Case-Laws Income Tax Mon, 18 Nov 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=761909