PCIT's Section 263 revision deemed mechanical; failed to identify AO errors; CBDT Circular supports assessee's stance.

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....Revision u/s 263 by CIT - Reopening of assessment u/s 147 initiated - PCIT has resorted to the revision proceedings u/s. 263 of the Act in a mechanical manner on the basis of the proposal of the Ld. AO. It has not been pointed out as to what error has been committed by the Ld. AO in accepting the explanation/evidences so furnished by the assessee in the process of verifying the nature of transactions. Even the CBDT's Circular cited by the Ld. PCIT in his order, in fact, comes to the support the assessee. - AT....