Sec. 263 of Income Tax Act, 1961 – Revision – The assessment was framed u/s 143(3) of the Act vide order dated 18.08.2016. Assuming powers conferred upon him by provisions of section 263 of the Act, the PCIT served notices to the assessee. PCIT was not convinced with the detailed submissions made by the assessee and accordingly, set aside the assessment order directing the AO to pass fresh assessment order after making thorough and detailed inquiries-on this particular issue only. Thus, the assesssee came into appeal. ITAT while allowing the appeal of the assessee set aside the order of PCIT and held that:–The AO, after considering the various submissions made by the assessee, has taken a possible view. Therefore, merely because the PCIT does not agree with the opinion of the Assessing Officer, he cannot invoke the provisions of section 263 of the Act to substitute his own opinion –SUNRAY COTSPIN (P.) LTD. V/s PR. CIT [2020] 79 ITR (TRIB) 193 (ITAT-DELHI)