No revision u/s 263 on the basis of “Borrowed Satisfaction”

Manoj Padaliya Vs PCIT (ITAT Ahmedabad) Conclusion:  For invoking the provisions of section 263, the foundation/ basis of initiation of 263 proceedings must emanate from the findings given by the AO in his assessment order of the assessee itself and section 263 could not be initiated on the basis of “borrowed satisfaction” (i.e on the basis of findings in assessment done in case of a third person). Held: Assessee had filed his income tax returns (ITR) for the AY 2013-14 and declared his total income at Rs. 3,31,310. Although the case of assessee was reopened, no additions were made by AO....