Section 263 can be invoked if no specific inquiry by AO against CBS expenses

State Bank of India Vs PCIT-2 (ITAT Mumbai)

ITAT note that the AO during the assessment proceedings had requested the assessee to furnish explanation in respect of such items of expenses and receipt appearing in the trading accounts and profit and loss accounts (either by way of excess or reduction) in comparison to last year. And AO also has asked for comparative details in the form of a chart as given above (supra). And in reply, it can be seen that the assessee in-turn had asked the AO to refer Schedule-14 ‘other income’ and Schedule-16 ‘operat

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