https://www.taxtmi.com/caselaws?id=752440 The ITAT Ahmedabad dismissed the assessee's appeal against PCIT's revision order u/s 263 regarding bogus LTCG/share transactions. The assessee argued PCIT lacked jurisdiction as the review wasn't initiated independently. However, ITAT held that despite AO's review proposal being internal procedure, PCIT conducted independent inquiry and properly exercised discretion under Explanation 2(a) to section 263, finding AO failed to make necessary enquiries regarding company strength, investment profile, and examination of five entities who purchased shares. PCIT's direction for fresh assessment was upheld. en-us Wed, 08 May 2024 00:00:00 +0530 Fri, 10 May 2024 06:58:22 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=752440 The ITAT Ahmedabad dismissed the assessee's appeal against PCIT's revision order u/s 263 regarding bogus LTCG/share transactions. The assessee argued PCIT lacked jurisdiction as the review wasn't initiated independently. However, ITAT held that despite AO's review proposal being internal procedure, PCIT conducted independent inquiry and properly exercised discretion under Explanation 2(a) to section 263, finding AO failed to make necessary enquiries regarding company strength, investment profile, and examination of five entities who purchased shares. PCIT's direction for fresh assessment was upheld. Case-Laws Income Tax Wed, 08 May 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=752440