Inadequate inquiry not amount to erroneous order, Section 263 cannot be invoked

Pramukh Realty Vs Pr. CIT (ITAT Rajkot)

Held that an inquiry made by the AO, considered inadequate by the Commissioner of Income Tax, cannot make the order of the Assessing Officer erroneous. Thus, the Commissioner of Income Tax by invoking revisionary powers u/s. 263 cannot impose his own understanding of the extent of inquiry.

Facts-

The assessee is a partnership firm engaged in the business of Real Estate. The PCIT found that the assessee has shown the gross valu

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