Challenges to PCIT jurisdiction under s.263 dismissed; assessment u/s.147 read with s.144B set aside, remand for fresh s.54F inquiry
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....ITAT dismisses the assessee's challenges to the PCIT's exercise of jurisdiction under s.263 and upholds the show-cause notice; grounds 1-3 are rejected. The Tribunal finds a direct connection between the recorded reasons and the sale of immovable property, concluding the AO ought to have examined the transaction, cost of acquisition, any prior capital gains adjustments and the assessee's claim under s.54F. ITAT holds the assessment order for A.Y. 2015-16 passed u/s.147 read with s.144B is erroneous and prejudicial to revenue, and confirms PCIT's action setting aside the matter to the file of the AO for fresh enquiry and determination of the s.54F claim.....