Revisionary power u/s 263 not invocable as facts already examined by AO

Sunayana Commercial Pvt. Ltd. Vs PCIT (ITAT Mumbai)

ITAT Mumbai held that revisionary power under section 263 of the Income Tax Act is not invocable for taking second opinion by Pr. CIT as the facts were already examined by AO.

Facts- Based on the information, notice u/s. 148 was issued on 15.06.2017 and notice u/s. 142(1) was issued on 29.11.2017. AO made disallowance u/s 14A towards Rs. 5,84,041/-.

Pr. CIT vide notices dated 19.03.2020, 05.03.2020 u/s 263 of the I

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