https://www.taxtmi.com/caselaws?id=242809 The Tribunal held that the Commissioner of Income Tax (CIT) did not validly exercise power under Section 263 as the Assessing Officer (AO) had thoroughly examined the transactions and the assessee provided substantial evidence. The order under Section 263 was canceled, and the assessee's appeal was allowed. The Tribunal emphasized that a mere change of opinion by the CIT is not sufficient grounds for invoking Section 263 when the AO's decision is not legally unsustainable. en-us Wed, 08 Jan 2014 00:00:00 +0530 Wed, 16 Mar 2016 10:48:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=242809 The Tribunal held that the Commissioner of Income Tax (CIT) did not validly exercise power under Section 263 as the Assessing Officer (AO) had thoroughly examined the transactions and the assessee provided substantial evidence. The order under Section 263 was canceled, and the assessee's appeal was allowed. The Tribunal emphasized that a mere change of opinion by the CIT is not sufficient grounds for invoking Section 263 when the AO's decision is not legally unsustainable. Case-Laws Income Tax Wed, 08 Jan 2014 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=242809