Tax Revision Deemed Unnecessary: PCIT's Error Claim on Partner's Capital Account Lacks Record Support, Revenue Neutral Situation.

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....Revision u/s 263 by CIT - Balances of partner’s capital account - where the balances are carried forward from the earlier assessment year and there are no movements in these accounts during the year, it is a revenue neutral exercise and thus, there is no prejudice which is caused to the Revenue and in any case, the matter has been examined by the AO and no further enquiries have been conducted by the ld PCIT. - the findings of the ld PCIT holding the order so passed by the AO erroneous in nature due to non-examination of the opening balances is clearly not borne out of records. - AT....