Section 263 SCN not justified in absence of specific finding of PCIT with respect to enquiries

Rishi Kiran Logistics Pvt. Ltd. Vs PCIT (ITAT Rajkot) It is revealed it is not the case that the AO has not made any enquiry. Indeed the Pr. CIT initiated proceedings under section 263 of the Act on the ground that the AO has not made enquiries or verification which should have been made in respect of disallowance under section 14A read with rule 8D of the Act. It is not the case of the Pr. CIT that the Ld. AO did not apply his mind to the issue on hand or he had omitted to make enquiries altogether. In the instant set of facts, the AO had made enquiries and after consideration of material pla...