Revision u/s 263 initiated twice by PCIT on short-term capital loss from penny stock (Sulabh Engineering Services Ltd.). AO had already verified the genuineness of the transactions twice (original + reassessment). Judicial resistance to arbitrary or repetitive invocation of section 263 when the Assessing Officer has exercised due diligence and formed a reasoned opinion. The ITAT reiterated that the revisional authority must not act merely as a supervisory authority unless there is palpable error or lack of enquiry that renders the assessment order unsustainable in law.(AY. 2016-16)   (ITA No. 2682/Mum/2024, Dated 11/03/2025)