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TMI Blog2016 (11) TMI 1019X X X X Extracts X X X X X X X X Extracts X X X X ..... ands on record. This leads to an inference that AO has considered all the relevant aspects about the assessment, and there is no case of lack of enquiry in this behalf during assessment. The level of enquiry in assessment proceedings is always a debatable proposition depending on the authority concerned. It has been held that conceptual difference on the manner of inquiry cannot make the assessmen ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... d order of the Tribunal whereby the Tribunal has allowed the appeal of the assessee and quashed the order of CIT under Section 263 of the Act. 2. Learned counsel for the appellant has raised the following substantial questions of law: (i) Whether the Tribunal was legally justified in quashing the order of the CIT passed u/s 263 specifically when the Assessing Officer did not carry out prop ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... that M/s. BPCL awarded contract to the assessee subject to arrangement of dedicated tanker for supply of petroleum products. This was arranged by the assessee by way of a tanker owned by associate concern. BPCL paid the transportation to assessee which is credited by it in the a/c of AKHK only and TDS is claimed by it as per certificate. From the assessment records, it emerges that the AO asked th ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... d that tanker receipts surplus has been shown by AKHK and is asssessed at same rate. All the transactions are duly disclosed and it cannot be held that AOs order is erroneous or prejudicial to the interest of revenue. 4. The Tribunal has thus given a finding that all the transactions are duly disclosed and it cannot be held that AOs order is erroneous or prejudicial to the interest of revenue ..... X X X X Extracts X X X X X X X X Extracts X X X X
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