2024 (2) TMI 347 - SCH - Income Tax

Validity of Revision u/s 263 - SCN stated that information had been received from the DDIT that during a search and seizure operation carried out payment made to the Assessee was detected as non-genuine commission payment - As per HC 2017 (9) TMI 1238 - DELHI HIGH COURT order of the CIT does not conform to the legal requirements of Section 263 of the Act. It was not enough for the CIT to reproduce the SCN, the reply thereto and give the conclusion. The impugned order of the CIT gives no reasons for the conclusion that the assessment order of the AO was erroneous and prejudicial to the interests of the Revenue - HELD THAT - We are not inclined to interfere with the impugned judgment and order passed by the High Court. Hence, the Special Leave Petition is dismissed. However, the question of law is left open.

Summary

The Supreme Court dismissed the Special Leave Petition without interfering with the impugned judgment and order passed by the High Court. The question of law is left open, and pending applications are disposed of.