PRINCIPAL COMMISSIONER OF INCOME TAX-9, KOLKATA vs. GITESH TIKMANI
In the result, these appeals are allowed and the substantial
ITAT/154/2021HC Calcutta14 Jun 2022
Bench: HON'BLE JUSTICE T. S. SIVAGNANAM,HON'BLE JUSTICE HIRANMAY BHATTACHARYYA
Section 263 could not have been exercised and such power could
have been exercised only when the assessing officer failed to conduct an
enquiry which is not the case of the assessee before this Court. With regard
to under what circumstances the power under Section 263 could be invoked
and the parameters to be fulfilled, reliance was placed
