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TMI Blog2018 (4) TMI 1721X X X X Extracts X X X X X X X X Extracts X X X X ..... ng Officer had raised multiple queries calling upon the assessee s response. The Tribunal was of the opinion that the Assessing Officer had carried out detailed inquiries. The Commissioner was incorrect in holding that no inquiries were carried out. The revisional powers, therefore, could not have been exercised. Tribunal has in the impugned judgment referred to the detailed correspondence betw ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... [ 1] Whether the order of the Appellate Tribunal cancelling the order of CIT under Section 268 of the Act is per verse as it has relied on irrelevant material and ignored relevant material and by assuming wrong fact that the AO had fully examined the impounded material ? [ 2] Whether the Appellate Tribunal was justified in law and on facts in hold ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... As can be seen from the questions framed, the issue pertains to exercise of power by the Commissioner under Section 263 of the Income-tax Act, 1961 [ the Act for short] revising the order of the Assessing Officer. Assessee is a developer of real estate and was subjected to search operations, during which certain unaccounted income was disclosed. This disclosure wa ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... r of Commissioner. In such judgment, the Tribunal observed that in the order of assessment, the Assessing Officer had raised multiple queries calling upon the assessee s response. The Tribunal was of the opinion that the Assessing Officer had carried out detailed inquiries. The Commissioner was incorrect in holding that no inquiries were carried out. The revisional powers, therefore, could not hav ..... X X X X Extracts X X X X X X X X Extracts X X X X
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