Revision u/s 263 - non application of mind by AO on search ...
PCIT's Section 263 Challenge Over Rs. 210 Crore Assessment Dismissed Due to Lack of Evidence, Mere Suspicion Insufficient.
June 19, 2021
Case Laws Income Tax AT
Revision u/s 263 - non application of mind by AO on search figures of income - PCIT has not brought any material to justify the alleged income of ₹ 210 crores. Thus, we note that allegation made by the ld PCIT is based merely on suspicion and conjecture. A mere observation that no proper details have been obtained, cannot be sufficient to come to a conclusion that the assessing officer did not make proper and adequate inquiries which he ought to have made in the given facts and circumstances of this case. - AT
View Source