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The ITAT held that the PCIT's revision under s.263 was unsustainable and quashed the revisionist order, affirming the assessment as not erroneous or prejudicial to Revenue. The AO had made appropriate enquiries, verified receipts and bank statements, and taken a plausible view; no incriminating material directly connecting the assessee's donations to a bogus donation racket was placed on record. The Tribunal found no specific enquiry left undone by the AO and observed that, if relevant incriminating material existed, Revenue's remedy was reopening under s.148 rather than s.263. The PCIT impermissibly substituted his opinion for the AO's within the limited scope of s.263; appeal allowed.
The ITAT held that the PCIT's revision under s.263 was unsustainable and quashed the revisionist order, affirming the assessment as not erroneous or prejudicial to Revenue. The AO had made appropriate enquiries, verified receipts and bank statements, and taken a plausible view; no incriminating material directly connecting the assessee's donations to a bogus donation racket was placed on record. The Tribunal found no specific enquiry left undone by the AO and observed that, if relevant incriminating material existed, Revenue's remedy was reopening under s.148 rather than s.263. The PCIT impermissibly substituted his opinion for the AO's within the limited scope of s.263; appeal allowed.
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