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Section 263 Cannot Replace AO’s View on Reopening Issues
Case Law Details
- Case Name
- Bipinkumar Rambhai Patel Vs PCIT (ITAT Ahmedabad)
- Appeal Number
- Only available for paid members
- Date of Judgement/Order
- Only available for paid members
- Related Assessment Year
- 2015-16
- Courts
- All ITAT, ITAT Ahmedabad
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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...
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