AO has taken view on a debatable issue after due enquiries- Section 263 cannot be invoked

PCIT Vs Britannia Industries Limited (Calcutta High Court)

The short issue involved in this case is whether the Commissioner could have invoked his power under Section 263 of the Act on the ground that the Assessing Officer did not conduct proper enquiry. We need not labour much to decide this issue as the learned Tribunal has elaborately discussed the factual position and brought out as to how the Assessing Officer had conducted an enquiry into the aspect as to how the amount received by the assessee from foreign entity tow

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