https://www.taxtmi.com/caselaws?id=312156 The ITAT Mumbai held that revision proceedings under section 263 initiated by the Pr.CIT based on the AO's recommendation regarding TPO's order under section 92CA(3) were invalid. The court found that the Pr.CIT relied on "borrowed satisfaction" from the AO rather than forming independent satisfaction about the assessment order being erroneous and prejudicial to revenue. Following the precedent in Alfa Laval case, the tribunal ruled that section 263 proceedings cannot be initiated with borrowed satisfaction and must satisfy twin conditions independently. The proceedings were set aside in favor of the assessee. en-us Wed, 27 Apr 2022 00:00:00 +0530 Sat, 03 Feb 2024 19:23:35 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=312156 The ITAT Mumbai held that revision proceedings under section 263 initiated by the Pr.CIT based on the AO's recommendation regarding TPO's order under section 92CA(3) were invalid. The court found that the Pr.CIT relied on "borrowed satisfaction" from the AO rather than forming independent satisfaction about the assessment order being erroneous and prejudicial to revenue. Following the precedent in Alfa Laval case, the tribunal ruled that section 263 proceedings cannot be initiated with borrowed satisfaction and must satisfy twin conditions independently. The proceedings were set aside in favor of the assessee. Case-Laws Income Tax Wed, 27 Apr 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=312156