https://www.taxtmi.com/caselaws?id=775506 The ITAT Surat held that Explanation 2 to section 263, effective from 1.6.2015, cannot be applied retrospectively to AY 2013-14. The CIT's revision under section 263 was invalid as it lacked proper reasoning and failed to identify any inquiry or verification omitted by the AO. The assessee had furnished detailed replies demonstrating adequate verification by the AO. The CIT did not specify what further inquiries were necessary or point out defects in the assessee's explanations. Consequently, the CIT's order was held to be an invalid exercise of jurisdiction and was quashed. The assessee's appeal was allowed. en-us Tue, 03 Jun 2025 00:00:00 +0530 Sat, 26 Jul 2025 08:39:47 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=775506 The ITAT Surat held that Explanation 2 to section 263, effective from 1.6.2015, cannot be applied retrospectively to AY 2013-14. The CIT's revision under section 263 was invalid as it lacked proper reasoning and failed to identify any inquiry or verification omitted by the AO. The assessee had furnished detailed replies demonstrating adequate verification by the AO. The CIT did not specify what further inquiries were necessary or point out defects in the assessee's explanations. Consequently, the CIT's order was held to be an invalid exercise of jurisdiction and was quashed. The assessee's appeal was allowed. Case-Laws Income Tax Tue, 03 Jun 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=775506