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2022 (12) TMI 441 - AT - Income TaxRevision u/s 263 - As per CIT, AO has failed to examine and verify the brought forwarded loss - HELD THAT:- From the papers on record, it is clear that AO had conducted enquiries with the assessee in respect of alleged brought forward loss. PCIT cannot substitute his opinion for that of the AO. It is also seen that ld. PCIT has not conducted any re-verification or prima facie investigation on his own to come to a conclusion that the order passed by the AO is erroneous to the interest of revenue. He also failed to notice that enquiries were made by the AO. The law on this issue is clear. See M/S. ANINDITA STEELS LTD. [2022 (2) TMI 397 - CALCUTTA HIGH COURT] We hold that the order passed u/s 263 is bad in law. Therefore, we quash the order passed by the ld. PCIT u/s 263 of the Act as bad in law and allow the appeal of the assessee.
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