CIT's Attempt to Replace AO's Opinion on Related Party Payments Deemed Impermissible u/s 263 and 40A(2)(a.

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....Revision u/s 263 - payment of conversion charges and job charges to related parties u/s 40A(2)(a) thoroughly examined by the AO - CIT had only tried to substitute his knowledge in technical aspect of the industry thereby trying to substitute his opinion on the impugned issue as against the opinion already framed by the AO - not permissible....