No revision u/s 263 on the basis of “Borrowed Satisfaction”

Manoj Padaliya Vs PCIT (ITAT Ahmedabad)

Conclusion:  For invoking the provisions of section 263, the foundation/ basis of initiation of 263 proceedings must emanate from the findings given by the AO in his assessment order of the assessee itself and section 263 could not be initiated on the basis of “borrowed satisfa

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