Allowing the appeal of the assessee the Tribunal held that ;Order was passed by the AO after conducting detailed enquiries on all issues. Because a few of parties had not responded to the notices issued under S.133 (6) the assessee might not be penalised for the conduct of the parties. The Commissioner had failed to point out the error committed by the Assessing Officer let alone such an error which could be considered to be prejudicial to the interests of the Revenue. The law did not permit the authority the exercise of revisionary powers to initiate fishing and roving enquiries. Accordingly the order of the Commissioner was to be quashed. ( AY.2012-13)
Abhimanyu Gupta v. CIT (2018) 64 ITR 611 (Chand) (Trib)
S. 263 : Commissioner – Revision of orders prejudicial to revenue – Order was passed by the AO after conducting detailed enquiries on all issues —Revision is not valid .