PCIT cannot invoke Section 263 to override A.O's plausible view on Section 56(2)(viib); applies only to residents.

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....Revision u/s 263 - addition u/s 56(2)(viib) - Section 56(2)(viib) of the Act s only applicable to residents and not to Non Residents. - In the instant case also Ld. A.O had considered various submissions of the assessee and taken a possible view. Therefore merely because Ld. PCIT did not agree to the opinion/information of the Ld. A.O who has conducted sufficient enquiry regarding the issue raised in this show cause notice issued by Ld. PCIT, provisions of Section 263 of the Act cannot be invoked in order to substitute his own information. - AT....