https://www.taxtmi.com/caselaws?id=769222 The HC upheld ITAT's decision quashing PCIT's revision order under Section 263. The PCIT had found the AO's order erroneous and prejudicial to revenue interests but failed to provide reasonable opportunity of hearing to the assessee before passing the ex parte order. The court held that where an AO applies mind and reaches logical conclusion, revisional authority cannot intervene merely due to different views or expecting more exhaustive reasoning, as this would convert revisional power into appellate review. The HC ruled that without proper hearing, the PCIT's finding was incorrect and upheld ITAT's decision favoring the assessee against revenue. en-us Tue, 08 Apr 2025 00:00:00 +0530 Tue, 22 Apr 2025 08:31:23 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=769222 The HC upheld ITAT's decision quashing PCIT's revision order under Section 263. The PCIT had found the AO's order erroneous and prejudicial to revenue interests but failed to provide reasonable opportunity of hearing to the assessee before passing the ex parte order. The court held that where an AO applies mind and reaches logical conclusion, revisional authority cannot intervene merely due to different views or expecting more exhaustive reasoning, as this would convert revisional power into appellate review. The HC ruled that without proper hearing, the PCIT's finding was incorrect and upheld ITAT's decision favoring the assessee against revenue. Case-Laws Income Tax Tue, 08 Apr 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=769222