INCOME TAX APPELLATE TRIBUNAL
SHRI KESHAV DUBEY, J, SHRI LAXMI PRASAD SAHU, ACJ
Buckeye Trust No.23 – Appellant
Versus
PCIT-2 – Respondent
ORDER
PER KESHAV DUBEY, JUDICIAL MEMBER:
This appeal at the instance of the assessee is directed against the order of ld. PCIT, Bengaluru-2 dated 29/03/2024 vide DIN & Order No. ITBA/REV/F/REV5/2023-24/1063614851(1) passed u/s. 263 of the Income Tax Act, 1961 (in short “the Act”) for the AY 2018-19.
2. The assessee has raised the following grounds of appeal:-
The grounds mentioned herein by the Appellant are independent and without prejudice to one another:
Grounds of appeal
A. General Ground
1. The Learned Principal Commissioner of Income Tax, Bengaluru - 2 ('Ld. PCIT') has erred in passing an order of revision under section 263 of the Income-tax Act, 1961 (the Act') which suffers from legal defects such as being passed in violation of the provisions of the Act and is devoid of merits and is contrary to the facts on record and applicable law and as such liable to be quashed.
2. The Ld. PCIT has finalized the impugned order with improper conclusion without considering the information, arguments and evidence provided by the Appellant.
B. Validity of revisionary proceedings under section 263 of the Act
1. The Impugned order passed by the Ld. PCIT is without jurisdiction as the twin conditions






















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