AO’s Reasoned Assessment Cannot Be Overridden by PCIT Without Error

Ucal Limited Vs PCIT (ITAT Chennai) Scrutiny Done, Queries Raised, Replies Given –  PCIT Cannot Rewrite AO’s View- Assessee filed its return declaring NIL income. Assessment was completed u/s 143(3) after detailed scrutiny. Later,  PCIT invoked revision u/s 263 on two issues: Allowability of ₹105.09 Cr impairment loss of investment in subsidiary claimed as business loss Late remittance of employees’ PF/ESI contribution of ₹1.67 Cr PCIT held that AO failed to conduct proper enquiry &  set aside the assessment as “erroneous & prejudicial to Revenue”. Before ITAT, Asses...