ITAT allowed the assessee's appeal and quashed the revisionary...

ITAT allowed the assessee's appeal and quashed the revisionary order passed u/s 263. It held that the assessment u/s 153A had been framed after obtaining mandatory approval u/s 153D and pursuant to specific queries raised by the AO on sale of assets below guideline value and possible application of s. 43CA. The assessee had duly responded, and the AO took a conscious view after inquiry. ITAT reaffirmed the distinction between "lack of inquiry" and "inadequate inquiry," holding that s. 263 can be invoked only in cases of lack of inquiry. Mere higher guideline value cannot, by itself, render the assessment erroneous and prejudicial to Revenue.