JR Industries v. PCIT (2022) 192 ITD 414 (Jaipur)(Trib.)

S. 263 : Commissioner-Revision of orders prejudicial to revenue-Pendency of appeal before CIT(A)-Commissioner can assume jurisdiction under section 263 in respect of issues which have not been considered and decided by Commissioner (Appeals)-Cash credits-Accommodation entries-Revision is held to be valid. [S. 68, 148]

Assessing Officer without carrying out any sort of investigation or verification or recording his satisfaction, treated sales as bogus and charged 25 per cent as income derived out of accommodation entries. Order of Assessing Officer being erroneous as well as prejudicial to interest of revenue, Commissioner was justified in exercising his revisionary jurisdiction and pointing out discrepancies in order passed by Assessing Officer. Commissioner can assume jurisdiction under section 263 in respect of issues which have not been considered and decided by Commissioner (Appeals)   (AY. 2011-12)

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