Section 263 Assessment: AO Obliged to Apply Mind & Pass Reasoned Order

MSK Project (India) JV Ltd. Vs ACIT (ITAT Ahmedabad)

Conclusion: The computation of income by AO giving effect to CIT’s direction was an assessment order which was appealable. The order passed by CIT(A), therefore, holding the assessment order to be not appealable was incorrect in law. It was deemed fit to restore the issue back to AO to verify the facts of the case and thereafter pass an order in accordance with the directions of CIT in his order passed u/s 263.

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