ADM Agro Industries Kota And Akola Pvt. Ltd. v. PCIT (2023)101 ITR 93 (SN) (Delhi) (Trib)

S. 263: Commissioner-Revision of orders prejudicial to revenue-Assessing officer made enquiries-Contention of the PCIT that examination not done incorrect-Contention that A.O. had only one day to pass order invalid-Revision not Justified.[S. 143(2)]

Held, that the A.O. had made enquiries and based on the reply given by the assessee the A.O. who had passed the order had satisfied himself by accepting the return of income of the assessee. Further, the A.O. had only one day time to pass the assessment order since the case was getting time-barred could not be a ground for the Principal Commissioner to exercise power conferred under section 263 of the Act. The Principal Commissioner had committed an error in exercising power under section 263. (AY. 2011-12).