In the result, the stay application filed by the assessee is dismissed
Bench: Shri Kul Bharatshri Manish Borad
section 263 of the Act, merely because he has a different opinion in the matter. It is only in cases of "lack of inquiry" that such a course of action would be open. The Ld. CIT himself admits that the AO did make enquiries however, in his view it was insufficient and in adequate enquiries, which is not a good