Invocation of s 263 unjustified where Commissioner intended to substitute his own view in place of that of the Assessing Officer without pointing out as to how the action of the Assessing Officer is erroneous in law or on facts

Satara Cattle Feed Industries (P) Ltd. v ACIT ITAT, Pune ITA No. 617/PN/2008 Assessment Year: 2003-2004 Decided on: 31 May 2011 Order G.S. Pannu, AM: This appeal by the assessee is directed against the revisional order of the Commissioner of Income tax-III, Pune (in short “the Commissioner”) dated 28.3.2008 passed under section 263 of the Income tax  Act, 1961 (in short “the Act”), setting aside the order dated 21.10.2005 passed by the Assessing Officer under section 143(3) of the Act, pertaining to the assessment year 2003-04. 2. In this appeal by the...