Order must be Erroneous and Prejudicial to Revenue Interests for Invoking S.263 of Income Tax Act: ITAT

The ITAT emphasized that for invoking Section 263 of the Income Tax Act, two conditions must be met: the order must be erroneous, and the error must be prejudicial to the interests of the revenue. In this case, the tribunal found that the original assessment was neither erroneous nor prejudicial to the revenue's interests, invalidating the PCIT's order. The ITAT ruled in favor of the taxpayer, stating that Section 263 cannot be invoked merely because of a difference in opinion unless these two conditions are satisfied.