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    <title>2022 (12) TMI 441 - ITAT KOLKATA</title>
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    <description>The tribunal held that the Principal Commissioner of Income Tax (PCIT) exceeded jurisdiction under Section 263 of the Income Tax Act, 1961, by quashing the PCIT&#039;s order as it duplicated the reasons for reassessment already examined by the Assessing Officer (AO). The reassessment proceedings initiated under Section 148 were deemed valid as the AO conducted adequate enquiries. The AO&#039;s authority was upheld, emphasizing that the PCIT cannot substitute their opinion for the AO&#039;s without independent verification. The PCIT&#039;s order was found to lack factual basis and procedural correctness, leading to its quashing. The appeal was allowed, and the PCIT&#039;s order was declared bad in law.</description>
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    <pubDate>Wed, 30 Nov 2022 00:00:00 +0530</pubDate>
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      <title>2022 (12) TMI 441 - ITAT KOLKATA</title>
      <link>https://www.taxtmi.com/caselaws?id=431324</link>
      <description>The tribunal held that the Principal Commissioner of Income Tax (PCIT) exceeded jurisdiction under Section 263 of the Income Tax Act, 1961, by quashing the PCIT&#039;s order as it duplicated the reasons for reassessment already examined by the Assessing Officer (AO). The reassessment proceedings initiated under Section 148 were deemed valid as the AO conducted adequate enquiries. The AO&#039;s authority was upheld, emphasizing that the PCIT cannot substitute their opinion for the AO&#039;s without independent verification. The PCIT&#039;s order was found to lack factual basis and procedural correctness, leading to its quashing. The appeal was allowed, and the PCIT&#039;s order was declared bad in law.</description>
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      <pubDate>Wed, 30 Nov 2022 00:00:00 +0530</pubDate>
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