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 a

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