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PCIT's Authority Limited: Cannot Revise Every AO Order u/s 263 of Income Tax Act. Judicial Clarification Provided.

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Full Text of the Document

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....Revision u/s 263 - Scope of Explanation 2 to section 263 - the said Explanation does not give unfettered power to the PCIT to assume revisional-jurisdiction to revise every order of the AO to re-examine the issues already examined during assessment-proceeding. It is judicially interpreted in several decisions that the intention of legislature behind introduction of Explanation 2 could not have been to enable the PCIT to find fault with each and every assessment-order in unlimited terms - AT....

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