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    <title>Revision under Section 263 set aside where AO conducted detailed, reasoned inquiry and PCIT failed independent enquiry</title>
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    <description>The ITAT set aside the PCIT&#039;s revision under section 263, holding that the AO had conducted a detailed, reasoned inquiry-examining bank records, financial statements and other material-and took a legally permissible view regarding the loan quantum; the PCIT failed to make any independent enquiry sufficient to dislodge the AO&#039;s cogent findings. The Tribunal emphasized the distinction between absence of investigation and a mere difference of opinion, and held that revisionary powers cannot be exercised without recording specific failure and prejudice caused by the AO&#039;s proceedings. Consequently the PCIT&#039;s exercise of revisional jurisdiction was held to be unjustified and the AO&#039;s assessment order was restored.</description>
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    <pubDate>Sat, 18 Oct 2025 09:08:21 +0530</pubDate>
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      <title>Revision under Section 263 set aside where AO conducted detailed, reasoned inquiry and PCIT failed independent enquiry</title>
      <link>https://www.taxtmi.com/highlights?id=93473</link>
      <description>The ITAT set aside the PCIT&#039;s revision under section 263, holding that the AO had conducted a detailed, reasoned inquiry-examining bank records, financial statements and other material-and took a legally permissible view regarding the loan quantum; the PCIT failed to make any independent enquiry sufficient to dislodge the AO&#039;s cogent findings. The Tribunal emphasized the distinction between absence of investigation and a mere difference of opinion, and held that revisionary powers cannot be exercised without recording specific failure and prejudice caused by the AO&#039;s proceedings. Consequently the PCIT&#039;s exercise of revisional jurisdiction was held to be unjustified and the AO&#039;s assessment order was restored.</description>
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      <pubDate>Sat, 18 Oct 2025 09:08:21 +0530</pubDate>
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