Section 263 cannot be invoked unless CIT himself made relevant enquiries and determines order to be erroneous

M/s. Indus Best Hospitality & Realtors Pvt. Ltd. Vs PR. CIT (ITAT Mumbai) We have considered rival contentions and carefully gone through the orders of the authorities below and found from record that CIT has invoked his power u/s.263 to examine the land development charges paid by the assessee to Smt. Sumitraben Chauhan. From the record, we found that payment was made for development. In the scrutiny order passed u/s. 143(3), the AO has made detailed enquiry with regard to the payment made to Smt. Sumitraben Chauhan for development of land which was attributable to Hard Murram supplied to...