https://www.taxtmi.com/caselaws?id=777931 ITAT RAJKOT - AT allowed the appeal, holding the PCIT's revision under s.263 unsustainable. The Tribunal found the AO had made full enquiries, examined documents produced during s.143(2)/142(1) proceedings, and took a plausible view on provident fund contributions-many paid within statutory grace periods and minor delays otherwise-before the SC decision in Checkmate. The order concluded s.263 cannot be used to substitute one opinion for another where records were examined and evidence was not shown to be fabricated; hence the AO's assessment was not erroneous or prejudicial to revenue. en-us Mon, 13 Jan 2025 00:00:00 +0530 Mon, 08 Sep 2025 13:37:07 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=777931 ITAT RAJKOT - AT allowed the appeal, holding the PCIT's revision under s.263 unsustainable. The Tribunal found the AO had made full enquiries, examined documents produced during s.143(2)/142(1) proceedings, and took a plausible view on provident fund contributions-many paid within statutory grace periods and minor delays otherwise-before the SC decision in Checkmate. The order concluded s.263 cannot be used to substitute one opinion for another where records were examined and evidence was not shown to be fabricated; hence the AO's assessment was not erroneous or prejudicial to revenue. Case-Laws Income Tax Mon, 13 Jan 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=777931