Invoking power u/s 263, merely on the basis of suspicion, is unjustified

Narendra Goel Vs PCIT (ITAT Delhi) Facts- Assessment u/s 143(3) was framed vide order dated 31.5.2017 determining income at Rs.17,82,584/-. Subsequently, the learned Pr.CIT on examination of record observed that the AO had not carried out requisite inquiry regarding advances from customers and also introduction of fresh capital. Accordingly, a notice u/s 263 of the Act was issued to the assessee. In response thereof, authorized representative of the assessee appeared and filed reply to the show cause notice issued by the learned Pr.CIT. However, the reply of the assessee was not found acceptab...