https://www.taxtmi.com/caselaws?id=782862 ITAT Kolkata allowed the assessee's appeal and quashed the revisionary order passed u/s 263. It held that the PCIT had assumed jurisdiction solely on the basis of a proposal from the AO pointing out alleged mistakes in the assessment u/s 143(3), without independently recording satisfaction that the assessment order was erroneous and prejudicial to the interests of the Revenue. Relying on binding HC precedents, the Tribunal reiterated that PCIT must form and record an objective opinion on error and prejudice and cannot invoke revisional powers mechanically or at the instance of the AO. en-us Tue, 26 Aug 2025 00:00:00 +0530 Fri, 05 Dec 2025 08:12:37 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=782862 ITAT Kolkata allowed the assessee's appeal and quashed the revisionary order passed u/s 263. It held that the PCIT had assumed jurisdiction solely on the basis of a proposal from the AO pointing out alleged mistakes in the assessment u/s 143(3), without independently recording satisfaction that the assessment order was erroneous and prejudicial to the interests of the Revenue. Relying on binding HC precedents, the Tribunal reiterated that PCIT must form and record an objective opinion on error and prejudice and cannot invoke revisional powers mechanically or at the instance of the AO. Case-Laws Income Tax Tue, 26 Aug 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=782862