Invoking section 263, for comprehensive inquiry made by AO, unsustainable

Sh. Jai Parkash Garg Vs PCIT (ITAT Delhi) Facts- AO noticed that assessee has deposited cash in the bank on the various dates. The assessee was called upon to explain the source of cash deposit with supporting evidence. In response thereto, the assessee explained that cash was deposited in the bank out of cash available with him out of withdrawal on earlier date, cash sales from the retail business & funds transferred from the OD a/c. Further AO noted that mostly cash was deposited in the bank in the round figure. That case was discussed with the counsel of the assessee who after discussio...