Shanti Prime Publication Pvt. Ltd.
Section 263 of the Income Tax Act, 1961 — Revision — The material on record would establish application of mind on the part of the AO while allowing the claim during the assessment proceedings and once such application of mind was discernible from the record, the proceedings under section 263 would amount to the Principal Commissioner having a different opinion and an assessment order cannot be treated as erroneous and prejudicial to the interests of revenue simply because in the opinion of the Principal Commissioner some other views are possible, thus, the order passed by the Principal Commissioner did not satisfy the pre-requisite condition of the assessment order being erroneous and prejudicial to the interests of revenue — Winvest Holdings (I) P. Ltd. vs. Assistant Commissioner of income tax [2019] 75 ITR (trib) 447(Chennai)