Invocation of provisions of section 263 by taking divergent view not justifiable: ITAT Ahmedabad

Hardevsingh P Chudasama Vs PCIT (ITAT Ahmedabad) ITAT Ahmedabad held that PCIT has taken divergent view from that of AO without giving the basis for invoking of provisions of section 263 of the Income Tax Act. Accordingly, order passed by PCIT u/s. 263 not justifiable. Facts- AO observed that the assessee deposited cash of Rs.47,69,500/- during the same period. Since the assessee has not responded to statutory notices AO proceeded on the basis section 144 of the Income tax Act. Subsequently, a show-cause notice dated 09.10.2019 was issued which was replied by the assessee dated 03.12.2019 and ...