Revision Fails: PCIT Cannot Invoke 263 Without Making the Very Enquiry He Says AO Missed

Vikram Sudhir Khurana Vs PCIT (ITAT Ahmedabad) Revision Fails: PCIT Cannot Invoke 263 Without Making the Very Enquiry He Says AO Missed Assessee purchased shares of WIRPPL worth ₹2.76 crore. Reassessment was triggered by Insight-P1 flag. AO issued detailed notices, examined source of investments, verified EPF withdrawal of ₹47.33 lakh, scrutinised nine bank credits, obtained PAN & confirmations of five lenders, checked bank statements, demat evidence & ledger accounts. After considering all materials, AO accepted the returned income. PCIT invoked s.263 alleging AO failed to obtain ...