Section 263 jurisdiction cannot be exercised if AO Conducted Proper Enquiry

Reliance Industries Ltd. Vs PCIT (ITAT Mumbai)

Upon perusal of assessment order under consideration, it is quite evident that an order was passed by Ld. AO u/s 143(3) r.w.s. 147 of the Act. One of the reasons to reopen the case was the allegation of Ld. AO that income from assets given on lease, though offered to tax under normal provisions, was not routed through Profit & Loss Account which has led to short-computation of Book Profits under MAT provisions. However, the assessee well explained the fact that the accountin

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