Section 263 Review: Inadequate Inquiry by Assessing Officer Not Grounds for Error; Conditions Not Met for Invocation.

Revision u/s 263 by CIT-A - The purported inadequacy in inquiry as alleged, cannot be stated to be 'erroneous' per se in so far as assessee is concerned, even if, such inaction of AO towards fuller enquiry is branded as 'prejudicial to the interest of Revenue'. Therefore, the mandatory twin conditions of Section 263 is also not found to be fulfilled when tested on the touchstone of taxability of share application money in the hands of assessee on the grounds of unproved source of source. - AT .....

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