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HC upheld ITAT's decision setting aside PCIT's order under Section 263, finding that PCIT failed to establish a prima facie opinion of assessment order being erroneous or prejudicial to revenue. The court emphasized that before modifying an assessment, PCIT must conduct necessary inquiries and consider the assessee's submitted replies. Merely alleging lack of investigation without specifying deficiencies does not justify reassessment. The ITAT's order was deemed legally sound, as the AO had already verified documents, investors' identities, and fund sources during original assessment proceedings.
HC upheld ITAT's decision setting aside PCIT's order under Section 263, finding that PCIT failed to establish a prima facie opinion of assessment order being erroneous or prejudicial to revenue. The court emphasized that before modifying an assessment, PCIT must conduct necessary inquiries and consider the assessee's submitted replies. Merely alleging lack of investigation without specifying deficiencies does not justify reassessment. The ITAT's order was deemed legally sound, as the AO had already verified documents, investors' identities, and fund sources during original assessment proceedings.
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