Invocation of section 263 is not justifiable if the same is the result of difference of opinion: ITAT Ahmedabad
ITAT Ahmedabad has rendered another interesting judgement on Section 147 r.w.s 144B, 263 of the Income Tax Act, 1961. It observed that the PCIT has overlooked all the evidence and has expressed a different view which amounts to second opinion and therefore invocation of section 263 is not justifiable.
The copy of the order is as under: