Section 263 Cannot Replace AO’s View on Reopening Issues

Bipinkumar Rambhai Patel Vs PCIT (ITAT Ahmedabad) Section 263 Cannot Substitute AO’s View: Revision Quashed Where Reopening Issue Was Examined The Ahmedabad “B” Bench of the Income Tax Appellate Tribunal allowed the assessee’s appeal and quashed the revision order u/s 263 for AY 2015-16, holding that the Principal Commissioner impermissibly sought to substitute his own view for that of the Assessing Officer. The reassessment had been reopened solely on alleged accommodation entries of ₹95.09 lakh. During reassessment, the AO called for details, examined replies, and considered affida...