Tax Review: PCIT's Section 263 Invocation Overruled; Assessment Order Found Accurate, Favoring Taxpayer's Land Purchase.

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....The assessee's case was selected for limited scrutiny under CASS. The PCIT observed that the assessee, along with two co-owners, had purchased an immovable property (land), each having an equal one-third share. It was held that Section 142(1) cannot extend the scope of a defective notice u/s 143(2) without PCIT's approval, which was not obtained. The notice u/s 142(1) mentioned the transfer of property, not its purchase. The assessee provided details regarding large cash deposits and property transfer during the assessment proceedings. The PCIT cannot invoke Section 263 when the assessee has provided detailed replies to the issues raised by the AO u/ss 143(2) and 142(1). The AO passed the assessment order after considering all relevant deta.........