Section 263 Set Aside for Relying on Uncorroborated Dumb Documents From Third-Party Search

Malay Multani Vs PCIT (ITAT Ahmedabad) Dumb Document Can’t Trigger 263: ITAT Ahmedabad Quashes Revision on Unproved TDR Cash Payment The ITAT quashed the Section 263 revision after holding that the Assessing Officer had already conducted proper enquiries into seized material, statements, bank records, and the TDR transaction. The Tribunal found that the PCIT relied on uncorroborated “dumb documents” from a third-party search, misread loose notings that lacked any nexus to the assessee, and even shifted allegations inconsistently between an individual and a firm. Since the AO had verified...