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    <title>2025 (6) TMI 909 - CALCUTTA HIGH COURT</title>
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    <description>The Calcutta HC upheld ITAT&#039;s decision setting aside PCIT&#039;s order under Section 263. PCIT had directed AO to re-examine share capital credits, identity of investors, and transaction genuineness. The court found PCIT failed to conduct required enquiry before forming prima facie opinion that AO&#039;s order was erroneous and prejudicial to revenue. PCIT did not consider assessee&#039;s reply or properly examine assessment files where AO had already verified genuineness, identity, and creditworthiness of share subscribers. PCIT merely concluded there was lack of enquiry without specifying what additional enquiry was needed. The revision was therefore unsustainable.</description>
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    <pubDate>Mon, 09 Jun 2025 00:00:00 +0530</pubDate>
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      <title>2025 (6) TMI 909 - CALCUTTA HIGH COURT</title>
      <link>https://www.taxtmi.com/caselaws?id=772796</link>
      <description>The Calcutta HC upheld ITAT&#039;s decision setting aside PCIT&#039;s order under Section 263. PCIT had directed AO to re-examine share capital credits, identity of investors, and transaction genuineness. The court found PCIT failed to conduct required enquiry before forming prima facie opinion that AO&#039;s order was erroneous and prejudicial to revenue. PCIT did not consider assessee&#039;s reply or properly examine assessment files where AO had already verified genuineness, identity, and creditworthiness of share subscribers. PCIT merely concluded there was lack of enquiry without specifying what additional enquiry was needed. The revision was therefore unsustainable.</description>
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      <pubDate>Mon, 09 Jun 2025 00:00:00 +0530</pubDate>
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