Section 263 Inapplicable if Detailed Enquiry Conducted & No Prejudice to Revenue Interests

Brahmaputra Property Hub Private Limited Vs ITO (ITAT Guwahati)

Appeal filed at the instance of the assessee is directed against the order of the Learned Principal Commissioner of Income Tax, Guwahati – 1, passed u/s 263 of the Income Tax Act, 1961 (in short ‘the Act’) dt. 30/03/2023, for Assessment Year 2018-19.

During the course of revisionary proceedings, it was stated by the assessee that secured loan was taken from SREI Infrastructure Finance Ltd. (in short “SREIIFL”) for the purpose of executing real estate and commercial business. Since the business was

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