https://www.taxtmi.com/caselaws?id=762851 ITAT Ahmedabad set aside PCIT's revision order u/s 263, ruling that the assessment order was not erroneous or prejudicial to revenue interest. The court held that section 263 proceedings cannot be initiated based on "borrowed satisfaction" from findings in third-party cases. PCIT failed to record specific satisfaction or identify defects in the original assessment order. The AO had conducted adequate inquiry, with the assessee providing bank statements, confirmations, and other supporting documents. Additionally, no disallowance was made in the payer company's assessment for similar payments, supporting the assessee's position. Appeal allowed. en-us Fri, 06 Dec 2024 00:00:00 +0530 Mon, 09 Dec 2024 08:44:20 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=762851 ITAT Ahmedabad set aside PCIT's revision order u/s 263, ruling that the assessment order was not erroneous or prejudicial to revenue interest. The court held that section 263 proceedings cannot be initiated based on "borrowed satisfaction" from findings in third-party cases. PCIT failed to record specific satisfaction or identify defects in the original assessment order. The AO had conducted adequate inquiry, with the assessee providing bank statements, confirmations, and other supporting documents. Additionally, no disallowance was made in the payer company's assessment for similar payments, supporting the assessee's position. Appeal allowed. Case-Laws Income Tax Fri, 06 Dec 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=762851