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The ITAT set aside the PCIT's revision under section 263, holding that the AO had conducted a detailed, reasoned inquiry-examining bank records, financial statements and other material-and took a legally permissible view regarding the loan quantum; the PCIT failed to make any independent enquiry sufficient to dislodge the AO's cogent findings. The Tribunal emphasized the distinction between absence of investigation and a mere difference of opinion, and held that revisionary powers cannot be exercised without recording specific failure and prejudice caused by the AO's proceedings. Consequently the PCIT's exercise of revisional jurisdiction was held to be unjustified and the AO's assessment order was restored.
The ITAT set aside the PCIT's revision under section 263, holding that the AO had conducted a detailed, reasoned inquiry-examining bank records, financial statements and other material-and took a legally permissible view regarding the loan quantum; the PCIT failed to make any independent enquiry sufficient to dislodge the AO's cogent findings. The Tribunal emphasized the distinction between absence of investigation and a mere difference of opinion, and held that revisionary powers cannot be exercised without recording specific failure and prejudice caused by the AO's proceedings. Consequently the PCIT's exercise of revisional jurisdiction was held to be unjustified and the AO's assessment order was restored.
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