No revision u/s 263 if AO’s view on the issue was a plausible view

Madurai Power –Corporation Pvt. Ltd. Vs PCIT (ITAT Chennai) Conclusion: AO while passing the re-assessment order u/s.147 did apply his mind to the issue and had accepted the claim of the assessee being satisfied with the explanation given by it during re-assessment proceedings. In such a scenario, the action of the AO couldn’t be held to be a view taken without enquiry or without application of mind. PCIT couldn’t substitute his views with that of the AO, if the AO’s view on the issue was a plausible view. Held: AO had raised queries on two issues i.e. (i) assessee claimed only 15% dep...