Section 263 Invalid When PCIT Questions AO’s Pen/Order Without Proof: ITAT Lucknow

Precious Buildtech Pvt Ltd Vs PCIT (ITAT Lucknow) No Power to Revise without Own Enquiry- Assessee Has No Control on AO’s Pen – PCIT Can’t Remand Without Investigation – 263 Order Invalid Where No Independent Enquiry Conducted   Assessee, engaged in real-estate business, had filed return declaring ₹81.54 lakh. The case was selected for scrutiny for examining high closing stock & mismatch between Service-tax & ITR turnover. AO, after issuing multiple notices u/s 142(1) & 143(2), accepted returned income vide assessment order dated 27.12.2019. PCIT, however, initi...