https://www.taxtmi.com/caselaws?id=764265 ITAT Surat held that PCIT's revision order u/s 263 was not sustainable where AO had adequately examined bogus purchase allegations during reassessment proceedings u/s 147. The tribunal found AO conducted sufficient inquiry, considered evidence, and took a plausible view in not making additions. Mere difference of opinion by PCIT cannot justify revision when AO's decision was legally sustainable and supported by evidence. Twin conditions for exercising jurisdiction u/s 263 were not fulfilled. PCIT's order was set aside and assessee's appeal was allowed. en-us Fri, 03 Jan 2025 00:00:00 +0530 Mon, 06 Jan 2025 12:56:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=764265 ITAT Surat held that PCIT's revision order u/s 263 was not sustainable where AO had adequately examined bogus purchase allegations during reassessment proceedings u/s 147. The tribunal found AO conducted sufficient inquiry, considered evidence, and took a plausible view in not making additions. Mere difference of opinion by PCIT cannot justify revision when AO's decision was legally sustainable and supported by evidence. Twin conditions for exercising jurisdiction u/s 263 were not fulfilled. PCIT's order was set aside and assessee's appeal was allowed. Case-Laws Income Tax Fri, 03 Jan 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=764265