CIT(A) Cannot Hide Behind PCIT’s 263 Order – Independent Application of Mind Mandatory

Renu Anandani Vs National Faceless Appeal Centre (ITAT Jabalpur) Assessment was reopened u/s 147 r.w.s. 143(3) on allegation that Assessee claimed bogus STCL in Ashutosh Paper Mills shares using fabricated back-dated contract notes. AO made addition of ₹22,16,080 including bogus loss of ₹21,72,628. Later, PCIT invoked 263 holding that shares credited to demat on 26.03.2012 valued at ₹3,56,680 were not proved to be the same as earlier offline purchases of ₹25,32,920, implying total unexplained investment of ₹28,89,600. AO, following 263 directions, added ₹7,16,972 u/s 69B, recompute...