The Hon’ble Tribunal observed that the issues flagged by the Commissioner had been explained and addressed by the assessee before the Commissioner. These explanations, though available on the record, had not been specifically rejected by the Commissioner. The Hon’ble Tribunal held that the Assessing Officer in this case had duly applied his mind. The order in appeal was arbitrary and whimsical and deserved to be quashed.(AY. 2017-18)
Gurcharan Singh v. PCIT (2023)101 ITR 539 (Chd) (Trib)
S. 263 : Commissioner-Revision of orders prejudicial to revenue-Cash deposits during demonetisation-AO raised detailed questions and assessee filed responses-AO applied mind to facts-Order of revision quashed.