https://www.taxtmi.com/caselaws?id=310760 ITAT Bangalore quashed PCIT's revision order u/s 263 regarding unexplained cash deposits during demonetization. AO conducted limited scrutiny of bank deposits, examined cash purchases/sales from May-October 2016, found inflation, and made additions on ad hoc basis. PCIT disagreed, wanting additions based on actual proved transactions. ITAT held AO's view was possible and pragmatic; PCIT cannot substitute their view for AO's under s.263 when AO's approach was reasonable. PCIT cannot direct fishing enquiry without showing AO's investigation was improper. Since limited scrutiny focused only on bank deposits and s.40A(3) wasn't part of original notice, that provision didn't apply. Assessee's appeal allowed. en-us Tue, 30 Aug 2022 00:00:00 +0530 Sat, 11 Nov 2023 08:26:26 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=310760 ITAT Bangalore quashed PCIT's revision order u/s 263 regarding unexplained cash deposits during demonetization. AO conducted limited scrutiny of bank deposits, examined cash purchases/sales from May-October 2016, found inflation, and made additions on ad hoc basis. PCIT disagreed, wanting additions based on actual proved transactions. ITAT held AO's view was possible and pragmatic; PCIT cannot substitute their view for AO's under s.263 when AO's approach was reasonable. PCIT cannot direct fishing enquiry without showing AO's investigation was improper. Since limited scrutiny focused only on bank deposits and s.40A(3) wasn't part of original notice, that provision didn't apply. Assessee's appeal allowed. Case-Laws Income Tax Tue, 30 Aug 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=310760