https://www.taxtmi.com/caselaws?id=775745 The ITAT Ahmedabad held that the AO's assessment order was neither erroneous nor prejudicial to Revenue's interest despite the absence of discussion on the DVO report. The AO exercised informed discretion, and the PCIT could not substitute its opinion for the AO's without finding lack of application of mind or reasoning. Both conditions under section 263-error and prejudice-must coexist, which was not established. The alleged prejudice was speculative and based on an untested valuation report not part of the record. The PCIT's revision under section 263 was held without jurisdiction and unsustainable. The revision order was quashed, and the assessee's appeal was allowed. en-us Mon, 28 Jul 2025 00:00:00 +0530 Wed, 30 Jul 2025 08:21:10 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=775745 The ITAT Ahmedabad held that the AO's assessment order was neither erroneous nor prejudicial to Revenue's interest despite the absence of discussion on the DVO report. The AO exercised informed discretion, and the PCIT could not substitute its opinion for the AO's without finding lack of application of mind or reasoning. Both conditions under section 263-error and prejudice-must coexist, which was not established. The alleged prejudice was speculative and based on an untested valuation report not part of the record. The PCIT's revision under section 263 was held without jurisdiction and unsustainable. The revision order was quashed, and the assessee's appeal was allowed. Case-Laws Income Tax Mon, 28 Jul 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=775745