https://www.taxtmi.com/caselaws?id=752643 ITAT Kolkata set aside Pr. CIT's revision order under Section 263 regarding share application money/share premium. The Pr. CIT held AO's order erroneous for lack of enquiry, invoking Explanation 2 to Section 263(1). However, ITAT found all discrepancies cited by Pr. CIT were factually incorrect as AO had conducted proper enquiries. The Tribunal held that Explanation 2 does not grant unbridled powers to set aside assessment orders merely stating AO should have made further enquiries without specifying deficiencies in existing enquiries or reasons for dissatisfaction with assessee's replies. Such approach would create endless litigation without assessment finality. Appeal allowed. en-us Mon, 13 May 2024 00:00:00 +0530 Tue, 14 May 2024 18:44:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=752643 ITAT Kolkata set aside Pr. CIT's revision order under Section 263 regarding share application money/share premium. The Pr. CIT held AO's order erroneous for lack of enquiry, invoking Explanation 2 to Section 263(1). However, ITAT found all discrepancies cited by Pr. CIT were factually incorrect as AO had conducted proper enquiries. The Tribunal held that Explanation 2 does not grant unbridled powers to set aside assessment orders merely stating AO should have made further enquiries without specifying deficiencies in existing enquiries or reasons for dissatisfaction with assessee's replies. Such approach would create endless litigation without assessment finality. Appeal allowed. Case-Laws Income Tax Mon, 13 May 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=752643