Section 263 Misuse: Revisionary Powers Cannot Be Based on Mere Suspicion, PCIT's Action Deemed Improper.

Revision u/s 263 - Invoking revisionary power u/s 263 of the Act is merely on suspicions is untenable. Further, the Ld. PCIT has not made any discussion on the issues pointed out by him and exercised the power conferred u/s 263 of the Act on the ground that the “explanation of the assessee seems to be plausible and it is not conclusive” which is not permissible u/s 263. - AT .....

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