No Section 263 revision for difference of opinion between AO & CIT

Maharashtra Engineering Vs PCIT (ITAT Pune)

The issue under consideration is whether order passed u/s 263 by CIT is justified in law?

It is noticed that the reopening of the assessment has been done for the specific purpose of examining the said purchases from C.R. enterprises. The A.O after considering the evidences produced came to the conclusion that the addition representing disallowance of 5% of the total purchases would meet the ends of  justice.   Thus, the reasons have been recorded for the

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