Recent case law of Mumbai Tribunal held that just because the opinion as arrived by the A.O is at a variation of the opinion of the learned Pr. CIT, would not grant the learned Pr. CIT the powers of revision u/s 263 of the Act
Section 263 of the act – Revision – during the reassessment, the A. O considered the issues of bogus purchase and estimating the GP addition @2.28% of the bogus purchase by passing…