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PCIT issued revision notice under s263 based on audit objections regarding unexplained property investments and bank deposits. The second notice dated 17.2.2022 introducing new issues exceeded statutory two-year limitation period. AO had previously examined property investments and ICICI bank account through s148 proceedings, conducting specific inquiries with documented evidence. ITAT determined this wasn't a case of inadequate inquiry as AO had performed necessary investigations and maintained proper records. Following precedents from SC and ITAT Chandigarh, the revision proceedings were deemed invalid both procedurally and substantively. The PCIT's order was quashed, and assessee's appeal was allowed, confirming that AO's original assessment addressing both disputed issues was proper and complete.
PCIT issued revision notice under s263 based on audit objections regarding unexplained property investments and bank deposits. The second notice dated 17.2.2022 introducing new issues exceeded statutory two-year limitation period. AO had previously examined property investments and ICICI bank account through s148 proceedings, conducting specific inquiries with documented evidence. ITAT determined this wasn't a case of inadequate inquiry as AO had performed necessary investigations and maintained proper records. Following precedents from SC and ITAT Chandigarh, the revision proceedings were deemed invalid both procedurally and substantively. The PCIT's order was quashed, and assessee's appeal was allowed, confirming that AO's original assessment addressing both disputed issues was proper and complete.
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