PCIT's Section 263 Revision Lacks Specific Errors, Relies on Insufficient Inquiry Without New Findings or Fact Verification.

Revision u/s 263 by CIT - PCIT himself has not carried out any examination or verification of facts and has simply directed the AO to ‘may verify Form 10CC and initial years assessment orders of each business based on the contract entered with Railways’. PCIT has merely set aside to indulge in verification of the same facts yet again without citing as to how the AO has committed any error except alleging no proper enquiry. - As no two persons possibly think alike, variance in their analysis, understanding and application of law in same or similar factual matrix by itself would not empower a superior authority to displace the view of the lower authority. - AT .....

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