Topic

AO's discretion

1 articleLatest March 2026
Section 263 IT Act | Revisionary Power Cannot Override AO's Reasoned Assessment Without Material Error : ITAT Dehradun
Case Law Analysis
|Income Tax Appellate Tribunal

Section 263 IT Act | Revisionary Power Cannot Override AO's Reasoned Assessment Without Material Error : ITAT Dehradun

ITAT Dehradun rules that revisionary powers under Section 263 of the Income Tax Act cannot be invoked merely to substitute the Assessing Officer's opinion unless a material error is established. The Tribunal quashed the PCIT's order, emphasizing that the AO's acceptance of loan details after due inquiry cannot be overturned without evidence of prejudice to revenue or procedural lapse.