In the result, all the four appeals of the assessee are allowed
Bench: Shri Rajpal Yadav, Vice-(Kz) & Shri Rajesh Kumar]
194 Taxman 324 (Del). 5.6. The Ld. A.R. also referred to explanation (2) of Section 263 as inserted w.e.f. 01.06.2015 which conferred the PCIT specific power to revise the assessment where AYs: 2013-14 to 2016-17 M/s Satyam Educational Health & Charitable Trust