https://www.taxtmi.com/caselaws?id=758946 The ITAT Ahmedabad allowed the assessee's appeal against the PCIT's revision order under section 263. The tribunal held that the PCIT failed to provide specific findings on how the assessment order was erroneous and prejudicial to revenue interests. The AO had already conducted proper enquiries regarding accommodation entries during section 147 proceedings. The PCIT impermissibly used section 263 proceedings merely to extend assessment timelines under section 147. The tribunal emphasized that to invoke section 263, the PCIT must demonstrate through independent findings that the AO took a legally unsustainable view, which was not established in this case. en-us Thu, 29 Aug 2024 00:00:00 +0530 Sat, 21 Sep 2024 08:00:05 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=758946 The ITAT Ahmedabad allowed the assessee's appeal against the PCIT's revision order under section 263. The tribunal held that the PCIT failed to provide specific findings on how the assessment order was erroneous and prejudicial to revenue interests. The AO had already conducted proper enquiries regarding accommodation entries during section 147 proceedings. The PCIT impermissibly used section 263 proceedings merely to extend assessment timelines under section 147. The tribunal emphasized that to invoke section 263, the PCIT must demonstrate through independent findings that the AO took a legally unsustainable view, which was not established in this case. Case-Laws Income Tax Thu, 29 Aug 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=758946