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TMI Blog2021 (10) TMI 404X X X X Extracts X X X X X X X X Extracts X X X X ..... e AO to make further inquiries to find out whether some error has been committed or not. In our view, before giving such general directions, it was incumbent upon the PCIT to show that the view taken by the AO is wholly unsustainable in law - revisional powers cannot be exercised in a perfunctory manner for directing some further and fuller inquiry made to merely find out if the earlier view taken is erroneous or not. In the instant case, an inquiry has been carried out and defense of the assessee was affirmed by the Assessing Officer as well as the JCIT. We thus see no scope for review for the purposes of making some unspelt inadequate inquiry . Thus, the ingredients for issuing show-cause notice under Section 263 of the Act are found ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... brief, are that the return of the assessee was subjected to search assessment for the AY 2012-13 in question and the assessment was completed by the Assessing Officer by passing the assessment order under Section 153A r.w.s. 143(3) of the Act dated 19.12.2016. 4. Thereafter, the PCIT called for the assessment records and opined that the assessment order so passed is erroneous insofar as prejudicial to the interest of the revenue on the issue of non-examination of arranging bogus purchase bills amounting to ₹ 1,24,02,421/- from M/s. Rajdhani Trading Company by the assessee. Similarly, another group company M/s. Indian Agro and Food Industries Limited is also stated to have availed the bogus purchase bills from M/s. Rajdhani Trading ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 7 18 of the paper-book). In response to the specific query raised by the Assessing Officer, the assessee has furnished a detailed submission on 30.06.2016 to defend its factual position (Reply placed at page Nos. 22 to 25 of the paper-book). It was thus contended that it is after perusal of the submissions and examination of facts and circumstances of the case, the Assessing Officer found merit in the plea of the assessee after proper application of mind. It is thus contended that the factual issue which has been examined threadbare by the Assessing Officer in search assessment, the reopening of the assessment on the same issue in the garb of review is highly unjustified. It was further submitted that the assessment order passed under Sec ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... pecific query, the assessee submitted certain submissions to support its case that the transactions undertaken with M/s. Rajdhani Trading Co. is bona fide and also submitted the copy of confirmation and tax audit report of the supplier company. All the bills and vouchers for such transactions were placed before the Assessing Officer for verification. It was also pointed out that the proprietor of the supplier company has not identified the assessee for the purposes of alleged bogus bills and such statement of the supplier company is vague and generic in nature. The request for cross-examination of the concerned person (Shri Jitendra Kumar Sahu) giving statement on behalf of the supplier company was not honoured. The proprietor of supplier n ..... X X X X Extracts X X X X X X X X Extracts X X X X
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