https://www.taxtmi.com/caselaws?id=763973 ITAT Mumbai upheld PCIT's revision under section 263 regarding share valuation and premium charged. AO rejected merchant banker's valuation report and adopted face value of Rs. 10 per share, bringing excess share premium to tax. ITAT held AO's order erroneous as no proper enquiry was conducted into share valuation report despite similar rejection in preceding assessment year. AO failed to record reasoned findings on substantial issue, merely passing order sheet entry without further investigation. ITAT emphasized AO's quasi-judicial role requiring fair assessment with proper reasoning. Revision under section 263 was correctly invoked against assessee. en-us Mon, 30 Dec 2024 00:00:00 +0530 Wed, 01 Jan 2025 08:33:05 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=763973 ITAT Mumbai upheld PCIT's revision under section 263 regarding share valuation and premium charged. AO rejected merchant banker's valuation report and adopted face value of Rs. 10 per share, bringing excess share premium to tax. ITAT held AO's order erroneous as no proper enquiry was conducted into share valuation report despite similar rejection in preceding assessment year. AO failed to record reasoned findings on substantial issue, merely passing order sheet entry without further investigation. ITAT emphasized AO's quasi-judicial role requiring fair assessment with proper reasoning. Revision under section 263 was correctly invoked against assessee. Case-Laws Income Tax Mon, 30 Dec 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=763973