CIT v. Chemsworth (P) Ltd. (2020) 275 Taxman 408 (Karn.)(HC)

S. 263 : Commissioner-Revision of orders prejudicial to revenue-AO had taken a plausible view-Merely on ground that enquiry conducted by AO was inadequate revision is held to be not valid. [S. 14A]

Assessee filed its return of income which was accepted by passing order u/s 143 (3) of the Act.  Revision order was passed on the ground that enquiry conducted by AO was inadequate. Tribunal quashed the revision order. On appeal by revenue the Court held the  assessee had filed all details before Assessing Officer that no expenditure was attributable to such exempt dividend income earned by it during year and Assessing Officer accepted same.  Since Assessing Officer had taken a plausible view in allowing claim of assessee, impugned invocation of revision under section 263 by Commissioner merely on ground that enquiry conducted by Assessing Officer was inadequate was unjustified. (AY.  2007-08)