Muzaffer Mahmood Khan v. PCIT (2020) 77 ITR 62 (SN) (Pune) (Trib.)

S. 263 : Commissioner-Revision of orders prejudicial to revenue-Sequence of events such as sale, purchase and other consequential transactions not discussed by AO-Revision is held to be valid. [S. 54F]

Tribunal held that  the, sequence of events such as sale, purchase and other consequential transactions not discussed by AO.  AO had referred to the Assistant Valuation Officer the valuation of land and the cost of acquisition as on April 1, 1981, but by the time of framing of assessment, the reply from the Assistant Valuation Officer had not been received by the AO and without considering it he had completed assessment and allowed the claim of the assessee under S.  54F without referring to it and recording the same in the assessment order. The AO  failed to examine the claim of the assessee in terms of law contemplated therein. Therefore this was a case of lack of enquiry. The PCIT rightly assumes jurisdiction. Revision is held to be justified. (AY. 2014-15)