https://www.taxtmi.com/caselaws?id=767951 The ITAT Delhi allowed the assessee's appeal against revision proceedings under section 263. The PCIT had identified 14 issues for scrutiny but claimed the AO examined only three. However, the tribunal found the AO had conducted elaborate enquiries on all relevant issues including section 80IA deductions, section 35(2AB) research expenditure claims, and customs duty differences. The TPO had also made transfer pricing adjustments after examining documents. The tribunal held that section 263 proceedings cannot be used for fishing enquiries or substituting the PCIT's views for the AO's plausible conclusions. The PCIT's actions lacked reasonable basis and constituted impermissible roving enquiries. en-us Wed, 26 Mar 2025 00:00:00 +0530 Fri, 28 Mar 2025 08:31:09 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=767951 The ITAT Delhi allowed the assessee's appeal against revision proceedings under section 263. The PCIT had identified 14 issues for scrutiny but claimed the AO examined only three. However, the tribunal found the AO had conducted elaborate enquiries on all relevant issues including section 80IA deductions, section 35(2AB) research expenditure claims, and customs duty differences. The TPO had also made transfer pricing adjustments after examining documents. The tribunal held that section 263 proceedings cannot be used for fishing enquiries or substituting the PCIT's views for the AO's plausible conclusions. The PCIT's actions lacked reasonable basis and constituted impermissible roving enquiries. Case-Laws Income Tax Wed, 26 Mar 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=767951