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    <title>2025 (12) TMI 412 - ITAT AHMEDABAD</title>
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    <description>ITAT allowed the assessee&#039;s appeal and quashed the revisionary order passed u/s 263. It held that the PCIT&#039;s assumption of jurisdiction was invalid as no independent inquiry or verification was conducted to demonstrate that the assessment order was erroneous and prejudicial to the interests of the Revenue. The PCIT merely alleged inadequate inquiry by the AO, reproduced the show cause notice and portions of the assessee&#039;s reply, but did not examine or discredit the materials on record. Since the AO had adopted a possible view after inquiry and with prior approval of the Additional CIT, the PCIT could not lawfully substitute his subjective standard of inquiry.</description>
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      <title>2025 (12) TMI 412 - ITAT AHMEDABAD</title>
      <link>https://www.taxtmi.com/caselaws?id=782872</link>
      <description>ITAT allowed the assessee&#039;s appeal and quashed the revisionary order passed u/s 263. It held that the PCIT&#039;s assumption of jurisdiction was invalid as no independent inquiry or verification was conducted to demonstrate that the assessment order was erroneous and prejudicial to the interests of the Revenue. The PCIT merely alleged inadequate inquiry by the AO, reproduced the show cause notice and portions of the assessee&#039;s reply, but did not examine or discredit the materials on record. Since the AO had adopted a possible view after inquiry and with prior approval of the Additional CIT, the PCIT could not lawfully substitute his subjective standard of inquiry.</description>
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