https://www.taxtmi.com/caselaws?id=757410 ITAT Ahmedabad held that PCIT was not justified in invoking revisional jurisdiction under Section 263 regarding accommodation entries. The AO had conducted detailed inquiries on alleged accommodation entries, which the assessee denied, with no further evidence establishing the transaction. The tribunal distinguished between lack of inquiry versus inadequate inquiry, noting that inadequate inquiry alone does not justify Section 263 proceedings merely due to differing opinions. Since the AO had examined the issue during assessment proceedings and applied his mind to legal issues, the revisional power was not available. The appeal was decided in favor of the assessee. en-us Wed, 14 Aug 2024 00:00:00 +0530 Fri, 23 Aug 2024 14:46:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=757410 ITAT Ahmedabad held that PCIT was not justified in invoking revisional jurisdiction under Section 263 regarding accommodation entries. The AO had conducted detailed inquiries on alleged accommodation entries, which the assessee denied, with no further evidence establishing the transaction. The tribunal distinguished between lack of inquiry versus inadequate inquiry, noting that inadequate inquiry alone does not justify Section 263 proceedings merely due to differing opinions. Since the AO had examined the issue during assessment proceedings and applied his mind to legal issues, the revisional power was not available. The appeal was decided in favor of the assessee. Case-Laws Income Tax Wed, 14 Aug 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=757410