PCIT's Section 263 Revision Blocked: No New Evidence Against AO's Consistent Deduction Claim u/s 80P for 2013-15.

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....Revision u/s 263 by PCIT - claim of deduction u/s 80P - When the rule of consistency has been applied by the ld AO, his order cannot be termed as erroneous without bringing any fresh facts on record. PCIT had not brought any evidence on record to prove that the facts prevailing in Asst Yea₹ 2013-14 and 2014-15 were different from that of facts prevailing in the year under consideration. Hence in our considered opinion, the conclusion of the ld PCIT that no enquiries were indeed carried out by the ld AO cannot be accepted and hence the revision order passed by him u/s 263. - AT....