Sec. 263 doesn't stipulate recording of satisfaction before issuance of SCN if order of AO appears to be erroneous
IT: Where assessee challenged show-cause notice by Commissioner under section 263 on account of non-recording of requisite satisfaction, since legal, remedy of filing appeal against order under section 263 has been provided, assessee should resort to alternative remedy of appeal
Regards
Prarthana Jalan
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