https://www.taxtmi.com/caselaws?id=777682 ITAT DELHI - AT quashed the Pr. CIT's invocation of s.263, holding the assessment framed u/s 147/143(3) was not shown to be erroneous and prejudicial to Revenue. The tribunal reiterated SC authority that s.263 is confined to cases where the AO's order is erroneous and prejudicial, and cannot be exercised where the AO's view is a possible view. It also followed HC guidance that unanswered queries do not prove lack of application of mind if the AO was satisfied by supplied material. The assessor's order stands; the assessee's grounds are allowed. en-us Thu, 28 Aug 2025 00:00:00 +0530 Wed, 03 Sep 2025 08:19:25 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=777682 ITAT DELHI - AT quashed the Pr. CIT's invocation of s.263, holding the assessment framed u/s 147/143(3) was not shown to be erroneous and prejudicial to Revenue. The tribunal reiterated SC authority that s.263 is confined to cases where the AO's order is erroneous and prejudicial, and cannot be exercised where the AO's view is a possible view. It also followed HC guidance that unanswered queries do not prove lack of application of mind if the AO was satisfied by supplied material. The assessor's order stands; the assessee's grounds are allowed. Case-Laws Income Tax Thu, 28 Aug 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=777682