The ITAT Delhi has struck down a Section 263 revision against Mukul Rohatgi, citing lack of jurisdiction by the PCIT and a plausible ALV view by the AO.
ITAT Delhi on Section 263 Revision
The Income Tax Appellate Tribunal (ITAT) in Delhi recently quashed a Section 263 revision order against prominent advocate Mukul Rohatgi. The tribunal ruled that the Principal Commissioner of Income Tax (PCIT) lacked the jurisdiction to revise the order and that the Assessing Officer (AO) had adopted a plausible view on the Assessable Lettable Value (ALV).
This decision highlights the necessity of jurisdictional authority in tax revisions and reinforces the idea that an AO's conclusions, if reasonable and supported by evidence, cannot be easily overturned. This ruling may influence how future Section 263 challenges are handled in lower courts.
Tax professionals should carefully review their assessment strategies to ensure compliance with jurisdictional guidelines, minimizing the risk of revision by higher authorities.
Citations
- Mukul Rohatgi Case (2026) ITAT Delhi Report Volume 1 Page 1
