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Distinction between "lack of inquiry and inadequate inquiry" emphasized. Assessee underwent rigorous assessment proceedings with multiple notices and replies. AO accepted returned income after due diligence, proper inquiry, and verification. Raising queries and examining records shows AO's application of mind. Entire record examined before concluding AO didn't examine any issue. Enquiry methodology prescribed followed. AO framed assessment considering assessee's replies. PCIT didn't conduct bare minimum inquiry before terming AO's order erroneous and prejudicial. Impugned PCIT order without jurisdiction, in excess of jurisdiction, irregular exercise of jurisdiction, null, void, illegal, improper exercise of revisionary jurisdiction u/s 263. Decided in assessee's favor.
Distinction between "lack of inquiry and inadequate inquiry" emphasized. Assessee underwent rigorous assessment proceedings with multiple notices and replies. AO accepted returned income after due diligence, proper inquiry, and verification. Raising queries and examining records shows AO's application of mind. Entire record examined before concluding AO didn't examine any issue. Enquiry methodology prescribed followed. AO framed assessment considering assessee's replies. PCIT didn't conduct bare minimum inquiry before terming AO's order erroneous and prejudicial. Impugned PCIT order without jurisdiction, in excess of jurisdiction, irregular exercise of jurisdiction, null, void, illegal, improper exercise of revisionary jurisdiction u/s 263. Decided in assessee's favor.
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