Held that merely because the Assessing Officer did not write specific reasons for accepting the explanation of the assessee cannot be reason enough to invoke powers under section 263, and non-mentioning of these reasons do not render the assessment order erroneous and prejudicial to the interest of the revenue. (AY. 2015-16)
Reliance Payment Solutions Ltd. v. PCIT (2022) 194 ITD 492 / 217 TTJ 153 / 212 DTR 297 (Mum.)(Trib.)
S. 263 : Commissioner-Revision of orders prejudicial to revenue-Higher rate of depreciation-Non-mentioning of specific reasons for accepting explanation of assessee by AO in assessment order-Revision is not valid. [S. 32]