Section 263: Clarifying "No Inquiry" vs "Inadequate Inquiry" in Tax Assessments; Revision Order Upheld for Doubtful Debts Case.

Revision u/s 263 - “no inquiry” v/s “inadequate inquiry” - there is a distinction between merely calling for information on a particular issue and considering such information with due application of mind if and when such information is actually provided by the assessee. Thus in the present facts, we are of the view that on the issue of allowing of provision for doubtful debts, the claim of the assessee was allowed which according to us is a case of “no inquiry” and not a case of “inadequate inquiry” and consequently a case of non application of mind to the material on record. - Revision order sustained - AT .....

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