PCIT cannot assume Section 263 jurisdiction when AO has made sufficient enquiry

Ruchi J Oil Pvt. Ltd Vs PCIT (ITAT Indore)

Conclusion: Since there was a detailed enquiry by AO on issue of equity shares to non-residents and after thoroughly discussing the issue in the assessment order, AO had taken a permissible view within the parameters of the law, there remained no room for PCIT to assume the jurisdiction u/s 263.

Held: Assessee issued equity shares to the resident and non resident companies. As per the Discounted Cash Flow (DCF) me

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