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Income Tax - Highlights / Catch Notes

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Revision u/s 263 - Scope of the affidavit relief upon by the AO ...


Section 263 Revision: AO's Use of Third-Party Affidavit Validated, No Contradictions Found by PCIT in Survey Matters.

September 12, 2023

Case Laws     Income Tax     AT

Revision u/s 263 - Scope of the affidavit relief upon by the AO - It is not self serving affidavit of the assessee but of concerned party from whom allegedly the assessee had benefited. There is no finding of Ld. PCIT as to which matter from the survey was contradicting the affidavit. The aforesaid narration of relevant queries made during re-assessment and replies of the assessee are sufficient to show that Ld. AO has asked for the affidavit, only to reaffirm that replies are supported with on oath deposition too. - AT

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