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    <title>2021 (5) TMI 75 - ITAT SURAT</title>
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    <description>The Tribunal quashed the order passed by the Principal Commissioner of Income Tax (PCIT) under Section 263 of the Income Tax Act, ruling in favor of the assessee. The Tribunal found that the Assessing Officer had conducted inquiries and considered evidence during the assessment proceedings, indicating that the original order was not erroneous. Additionally, the Tribunal determined that Explanation 2 to Section 263, which deems an order erroneous if inquiries are lacking, did not apply retroactively to the assessment year in question. Consequently, the appeal of the assessee was allowed, and the PCIT&#039;s order was overturned.</description>
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    <pubDate>Wed, 28 Apr 2021 00:00:00 +0530</pubDate>
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      <title>2021 (5) TMI 75 - ITAT SURAT</title>
      <link>https://www.taxtmi.com/caselaws?id=407196</link>
      <description>The Tribunal quashed the order passed by the Principal Commissioner of Income Tax (PCIT) under Section 263 of the Income Tax Act, ruling in favor of the assessee. The Tribunal found that the Assessing Officer had conducted inquiries and considered evidence during the assessment proceedings, indicating that the original order was not erroneous. Additionally, the Tribunal determined that Explanation 2 to Section 263, which deems an order erroneous if inquiries are lacking, did not apply retroactively to the assessment year in question. Consequently, the appeal of the assessee was allowed, and the PCIT&#039;s order was overturned.</description>
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      <pubDate>Wed, 28 Apr 2021 00:00:00 +0530</pubDate>
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