PCIT's Order Invalidated: Lack of Due Process in Classifying Lender as Shell Company, Flawed Creditworthiness Assessment.

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....Validity of Revision u/s 263 - The order passed by the PCIT suffers from lack of due opportunity of hearing as the PCIT while making such observation that the lender Company was classified as shell company and relied on some statement recorded but before such finding was recorded which was prejudicial to the right of the assessee, no opportunity of hearing was given to the assessee. The reliance of credit worthiness of lender Company which dominated the track for PCIT to arrive at a finding to invoke Section 263 was defective. - HC....