https://www.taxtmi.com/caselaws?id=762231 HC held that revision under s.263 was improper where the PCIT assumed jurisdiction merely by differing in opinion; AO had conducted inquiry into survey records and treated the voluntary surrender as professional/business income, a plausible view. The Tribunal rightly found the principal CIT ignored the factual and legal record and failed to show how the assessment was erroneous and prejudicial to revenue. Absent examination of survey documents or reasons demonstrating error, a change of opinion did not justify revision. Decision affirmed in favour of the assessee. en-us Mon, 18 Nov 2024 00:00:00 +0530 Sat, 20 Sep 2025 12:36:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=762231 HC held that revision under s.263 was improper where the PCIT assumed jurisdiction merely by differing in opinion; AO had conducted inquiry into survey records and treated the voluntary surrender as professional/business income, a plausible view. The Tribunal rightly found the principal CIT ignored the factual and legal record and failed to show how the assessment was erroneous and prejudicial to revenue. Absent examination of survey documents or reasons demonstrating error, a change of opinion did not justify revision. Decision affirmed in favour of the assessee. Case-Laws Income Tax Mon, 18 Nov 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=762231