PCIT v. Minal Nayan Shah (2020) 428 ITR 23/ 275 Taxman 540 (Guj.)(HC)

S. 263 : Commissioner-Revision of orders prejudicial to revenue-Purchase of three units-Possible view -Revision is held to be not valid [S. 54, 54F]

Dismissing the appeal of the revenue the Court held that on the facts the order of the Tribunal quashing the revisional order passed by the Principal Commissioner under section 263 was not erroneous. The findings of facts recorded by the Tribunal was that one of the requisite conditions for the exercise of power under section 263 the Commissioner should consider the assessment order to be erroneous and prejudicial to the interests of the Revenue was not satisfied and in arriving at such conclusion the Tribunal had assigned cogent reasons. No question of law arose. (AY. 2014-15)