https://www.taxtmi.com/caselaws?id=783954 The dominant issue was whether revision under s. 263 was valid on the ground that the AO allegedly accepted deductions under ss. 35(2AB), 80-IB and 80-IC without proper verification (including absence of Form 3CL on record). The ITAT held that s. 263 requires the PCIT to record specific findings that the assessment order is both erroneous and prejudicial to revenue; mere direction for further enquiry, or substitution of the PCIT's perception of "proper enquiry" for a possible view taken on audited accounts and supporting material, is impermissible, particularly where the deductions were regularly claimed for existing units. Consequently, the s. 263 order was quashed and the assessee's appeal was allowed. en-us Fri, 14 Nov 2025 00:00:00 +0530 Mon, 22 Dec 2025 14:58:47 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=783954 The dominant issue was whether revision under s. 263 was valid on the ground that the AO allegedly accepted deductions under ss. 35(2AB), 80-IB and 80-IC without proper verification (including absence of Form 3CL on record). The ITAT held that s. 263 requires the PCIT to record specific findings that the assessment order is both erroneous and prejudicial to revenue; mere direction for further enquiry, or substitution of the PCIT's perception of "proper enquiry" for a possible view taken on audited accounts and supporting material, is impermissible, particularly where the deductions were regularly claimed for existing units. Consequently, the s. 263 order was quashed and the assessee's appeal was allowed. Case-Laws Income Tax Fri, 14 Nov 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=783954