HC upholds appeal, sets aside PCIT order under Section 263 for lack of independent review and valuation errors

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....The HC upheld the Tribunal's decision allowing the assessee's appeal and setting aside the PCIT's order passed under Section 263. The PCIT wrongly invoked revisionary jurisdiction solely on the AO's reference without independently applying its mind. The valuation of leasehold land and building was upheld as fair, based on a registered valuer's report and disclosed facts, negating applicability of Section 56(2)(x) since the property acquisition predated the provision's insertion. The PCIT's factual errors regarding the AO's consideration of these aspects amounted to non-application of mind. Additionally, the PCIT failed to address the assessee's contention under Section 43B that reversal of provisions previously disallowed as expenses cannot.........