Section 263 – Revision merely on DCIT suggestion & without independent judgment, not valid in law

Brief of the Case

ITAT Pune held In the case of Span Overseas Ltd. vs. CIT that from the show cause notice, it is clear that the CIT has invoked the provisions of section 263 on the proposal submitted by the DCIT and deficiencies in the assessment order pointed out by the DCIT. As per the provisions of section 263, it is the CIT who has to examine the records and thereafter form an independent opinion that the order passed by the Assessing Officer is erroneous in so far as it prejudicial to the i

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