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PCIT invoked section 263 against order of AO accepting valuation report of merchant banker determining share value at premium. ITAT held that AO failed to make proper enquiry and record reasons for accepting valuation report, especially when similar report was rejected in preceding year for assessee. AO passing order without proper enquiry and reasons on substantial issue like share valuation made order erroneous and amenable to revision u/s 263. Decided against assessee.