Sh. Vinod Kumar Gupta, Alwar vs. PCIT(Central), Jaipur
In the result, both appeals of the assessee stands dismissed
ITA 661/JPR/2024[2018-19]Status: DisposedITAT Jaipur29 Aug 2024AY 2018-19
Bench: moving towards the facts of the case we would like to mention that the assessee has assailed the appeal in ITA No.644/JP/2024 on the following grounds; "1. Under the facts and circumstances of the case, order passed by the Ld. PCIT u/s 263 is illegal & bad in law and the same be quashed. 2. The Ld. PCIT has erred on facts and in law in holding that the
For Appellant: Sh. P. C. Parwal, CAFor Respondent: Sh. Arvind Kumar, CIT-DR
Section 115BSection 127Section 133ASection 142(1)Section 143(2)Section 143(3)Section 263
…4 (Surat) (Trib.) Where any inquiry, even inadequate was made by AO, that would not give occasion to invoke jurisdiction u/s 263 merely because Commissioner had different opinion unless view taken by AO is unsustainable in law. Dhanraj Chhipa Vs. PCIT (2023) 225 DTR 315 (Jodhpur) (Trib.) If there was any enquiry and a possible view was taken by the AO, it would not give occasion to the CIT to pass orders u/s 263 merely because he has a different opinion in the matter. Since the AO has examined the assessee's case and made complete enquiry regarding the issue raised in the revision proceeding, the Principal CIT w…