An inadequate enquiry on the part of the AO would not, by itself, give occasion to the Commissioner to pass orders under s 263 merely because he has a different opinion on the matter

Fab India Overseas Pvt. Ltd. Vs CIT (Delhi High Court)- An inadequate enquiry on the part of the AO would not, by itself, give occasion to the Commissioner to pass orders under s 263 merely because he has a different opinion on the matter. Issues, in respect of which the assessee has preferred an appeal before the CIT(A), could not have been taken up by the Commissioner while exercising his powers under s 263(1). Failure to conduct an enquiry on part of the AO with regard to international transactions made by the assessee with its associates gives jurisdiction to CIT to exercise power under ...