No section 263 revision by PCIT based on borrowed satisfaction

Grasim Industries Ltd. Vs PCIT (ITAT Mumbai)

Conclusion: Since the revision proceedings u/s 263 had been apparently triggered only based on borrowed satisfaction i.e Audit Objection and not based on independent application of mind by PCIT therefore, the revision order passed by PCIT u/s 263 was hereby directed to be quashed.

Held: Assessee had filed its original return of income which was later revised declaring total income of Rs. 283,15,81,630/- under no

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