Section 263 Jurisdiction Fails – AO’s Plausible View in Search Cases Upheld

Zari Silk (India) Pvt. Ltd. Vs. PCIT (ITAT Jaipur) Facts  A search u/s 132 was conducted on 23.11.2021 at the premises of Zari Silk (India) Pvt. Ltd. & its director, Shri Arun Palawat. Assessees filed returns declaring losses. AO completed assessments u/s 143(3) r.w.s. 148B after detailed enquiry, making additions of ₹33.90 lakh (company) & ₹88.24 lakh (individual) as “income from other sources”. Orders were passed with prior approval of Addl. CIT u/s 148B. Later, PCIT (Central) invoked revisionary powers u/s 263 on the ground that AO should have assessed such amounts u/s 69A/...