Held that there was a distinction between merely calling for information on a particular issue and considering such information with due application of mind if and when such information were actually provided by the assessee. The Assessing Officer merely seeking information on an issue and the assessee not giving the full information, could not be considered sufficient. It is necessary that the Assessing Officer actually apply his mind to the information supplied by the assessee and after considering the information form an opinion as to whether the assessee were actually entitled to deduction. The required information was not furnished by the assessee. This would fall in the category of non-inquiry and not a case of inadequate inquiry. Revision is justified.(AY.2016-17)
Jubilant Pharmova Ltd. v. PCIT (2023)107 ITR 707 (Delhi) (Trib)
S. 263 : Commissioner-Revision of orders prejudicial to revenue-Failing to furnish required information-No further enquiry-Revision is justified. [S. 143(3)]