https://www.taxtmi.com/caselaws?id=780568 ITAT MUMBAI - AT allowed the appeal, setting aside the PCIT's revision under s.263. The Tribunal held s.263 is supervisory, requiring the impugned order to be both erroneous and prejudicial; those twin conditions were not satisfied because the AO adopted a legally tenable view after inquiry by disallowing expenditure as non-genuine. Payments routed through banking channels, recorded in accounts and reflected in trading results explained the source, so s.69C/ss.115BBE and penalty u/s.271AAC were inapplicable. The PCIT's substitution of his own interpretation was held impermissible. en-us Mon, 13 Oct 2025 00:00:00 +0530 Sat, 01 Nov 2025 08:17:01 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=780568 ITAT MUMBAI - AT allowed the appeal, setting aside the PCIT's revision under s.263. The Tribunal held s.263 is supervisory, requiring the impugned order to be both erroneous and prejudicial; those twin conditions were not satisfied because the AO adopted a legally tenable view after inquiry by disallowing expenditure as non-genuine. Payments routed through banking channels, recorded in accounts and reflected in trading results explained the source, so s.69C/ss.115BBE and penalty u/s.271AAC were inapplicable. The PCIT's substitution of his own interpretation was held impermissible. Case-Laws Income Tax Mon, 13 Oct 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=780568