https://www.taxtmi.com/caselaws?id=784219 The dominant issue was whether the PCIT validly assumed jurisdiction under s.263 to revise a reassessment order under ss.143(3) r.w.s. 147 for alleged erroneous allowance of deduction under s.80-IA(4). The ITAT held that the supposed prejudice could not arise from the reassessment order because, in view of binding judicial precedent, the AO in s.147 proceedings could not have disallowed the s.80-IA claim on the stated ground. The ITAT further held that a revision initiated solely on the AO's proposal, without the PCIT's independent examination and satisfaction, is unsustainable. Consequently, the s.263 order was held to be without jurisdiction and was quashed; the appeal was allowed. en-us Tue, 09 Dec 2025 00:00:00 +0530 Wed, 31 Dec 2025 09:17:37 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=784219 The dominant issue was whether the PCIT validly assumed jurisdiction under s.263 to revise a reassessment order under ss.143(3) r.w.s. 147 for alleged erroneous allowance of deduction under s.80-IA(4). The ITAT held that the supposed prejudice could not arise from the reassessment order because, in view of binding judicial precedent, the AO in s.147 proceedings could not have disallowed the s.80-IA claim on the stated ground. The ITAT further held that a revision initiated solely on the AO's proposal, without the PCIT's independent examination and satisfaction, is unsustainable. Consequently, the s.263 order was held to be without jurisdiction and was quashed; the appeal was allowed. Case-Laws Income Tax Tue, 09 Dec 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=784219