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ITAT allowed the assessee's appeal and quashed the revisionary order passed u/s 263. It held that the PCIT's assumption of jurisdiction was invalid, as no independent inquiry, verification, or examination of evidence was undertaken beyond the existing assessment record. The PCIT merely reproduced the AO's show cause notice and portions of the assessee's reply without analyzing or rebutting the material filed. ITAT observed that the AO had conducted inquiries, adopted a possible view in law, and obtained prior approval of the Addl. CIT. In such circumstances, the PCIT could not invoke s.263 on a vague allegation of inadequate inquiry without demonstrating any specific error rendering the assessment order erroneous and prejudicial to the Revenue.
ITAT allowed the assessee's appeal and quashed the revisionary order passed u/s 263. It held that the PCIT's assumption of jurisdiction was invalid, as no independent inquiry, verification, or examination of evidence was undertaken beyond the existing assessment record. The PCIT merely reproduced the AO's show cause notice and portions of the assessee's reply without analyzing or rebutting the material filed. ITAT observed that the AO had conducted inquiries, adopted a possible view in law, and obtained prior approval of the Addl. CIT. In such circumstances, the PCIT could not invoke s.263 on a vague allegation of inadequate inquiry without demonstrating any specific error rendering the assessment order erroneous and prejudicial to the Revenue.
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