Share Valuation Already Verified- Once AO Examines Accepts, 263 Cannot Reopen

Kishore Kumar Gurnani Vs ACIT (ITAT Jaipur)

Both assessees had sold equity shares of M/s Vankon Moduler Pvt. Ltd. &  declared capital gains after computing fair market value @ ₹32 per share. Their assessments were completed u/s 143(3) after compulsory scrutiny, where AO issued notices u/s 143(2) & 142(1) &  specifically recorded that he had examined all details &  verified the facts, &  accordingly accepted the returned income.

PCIT invoked revision u/s 263, holding that AO passed the orders in a “routine &  casual manner” without verifying

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