https://www.taxtmi.com/caselaws?id=462431 The Tribunal allowed the assessee's appeal under section 263 of the Income Tax Act, 1961, setting aside the PCIT's revision order. The Tribunal held that the PCIT improperly invoked section 263 merely to substitute the AO's opinion without identifying specific errors, which constitutes an impermissible change of opinion. The revision order was found invalid due to violation of natural justice principles, as neither the show cause notice nor the order was properly served on the assessee. The Tribunal concluded that the PCIT lacked jurisdiction to revise the AO's reassessment order that had accepted the returned income after detailed consideration. en-us Thu, 13 Oct 2022 00:00:00 +0530 Sun, 22 Jun 2025 13:13:20 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=462431 The Tribunal allowed the assessee's appeal under section 263 of the Income Tax Act, 1961, setting aside the PCIT's revision order. The Tribunal held that the PCIT improperly invoked section 263 merely to substitute the AO's opinion without identifying specific errors, which constitutes an impermissible change of opinion. The revision order was found invalid due to violation of natural justice principles, as neither the show cause notice nor the order was properly served on the assessee. The Tribunal concluded that the PCIT lacked jurisdiction to revise the AO's reassessment order that had accepted the returned income after detailed consideration. Case-Laws Income Tax Thu, 13 Oct 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=462431