https://www.taxtmi.com/caselaws?id=782935 ITAT Ahmedabad quashed the revisionary orders passed u/s 263 in respect of assessments framed u/s 153C. It held that the PCIT failed to establish the twin jurisdictional conditions that the assessment orders were both "erroneous" and "prejudicial to the interests of the Revenue." The AO had issued detailed notices, examined seized materials, obtained project-wise and year-wise details, and adopted a plausible view after due enquiry. The PCIT neither conducted any independent verification nor dealt with the assessee's comprehensive rebuttals, and recorded no specific finding of error in the assessments. Mere preference for deeper enquiry or a different view amounted to a change of opinion, insufficient for valid assumption of jurisdiction u/s 263. The assessee's appeals were allowed. en-us Thu, 27 Nov 2025 00:00:00 +0530 Sat, 06 Dec 2025 08:46:09 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=782935 ITAT Ahmedabad quashed the revisionary orders passed u/s 263 in respect of assessments framed u/s 153C. It held that the PCIT failed to establish the twin jurisdictional conditions that the assessment orders were both "erroneous" and "prejudicial to the interests of the Revenue." The AO had issued detailed notices, examined seized materials, obtained project-wise and year-wise details, and adopted a plausible view after due enquiry. The PCIT neither conducted any independent verification nor dealt with the assessee's comprehensive rebuttals, and recorded no specific finding of error in the assessments. Mere preference for deeper enquiry or a different view amounted to a change of opinion, insufficient for valid assumption of jurisdiction u/s 263. The assessee's appeals were allowed. Case-Laws Income Tax Thu, 27 Nov 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=782935