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ITAT held that the PCIT's revision order under Section 263 was invalid. The tribunal found no substantive evidence to support the claim of bogus purchases and determined that the Assessing Officer's original assessment was a plausible view. The PCIT's directions contradicted each other, with general instructions for de novo assessment conflicting with specific directions to tax 25% of alleged bogus purchases. Without invoking Explanation 2 to Section 263, the revision order lacked legal merit. The tribunal ultimately allowed the assessee's appeal, nullifying the PCIT's revision order and upholding the original assessment.
ITAT held that the PCIT's revision order under Section 263 was invalid. The tribunal found no substantive evidence to support the claim of bogus purchases and determined that the Assessing Officer's original assessment was a plausible view. The PCIT's directions contradicted each other, with general instructions for de novo assessment conflicting with specific directions to tax 25% of alleged bogus purchases. Without invoking Explanation 2 to Section 263, the revision order lacked legal merit. The tribunal ultimately allowed the assessee's appeal, nullifying the PCIT's revision order and upholding the original assessment.
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