Change of Opinion Not 263: PCIT’s Roving Enquiry Direction Held Illegal

Safal Constructions (India) Pvt. Ltd. Vs PCIT (ITAT Ahmedabad) Change of Opinion Not 263: PCIT’s Roving Enquiry Direction Held Illegal Assessments for both years were completed u/s 153C on 30.09.2022 after mandatory approval u/s 153D. The AO had issued detailed notices u/s 142(1) (dated 12.02.2022 for AY 2018-19 and 10.02.2022 for AY 2019-20) and Assessee filed comprehensive replies (dated 07.03.2022 & 11.02.2022) containing page-wise rebuttal of every seized document recovered from the residence of one Shri Suresh Thakkar. AO, after verification, drew no adverse inference other than min...