PCIT (Central) v. Rani Sati Agro Tech (P.) Ltd. (2024) 298 Taxman 498 (Cal.)(HC)

S. 263 : Commissioner-Revision of orders prejudicial to revenue- Cash credits-Share application money-Second revisionery order-Order of Tribunal setting aside second revisionery order is affirmed. [S. 68, 143(3), 260A]

Commissioner invoked revisionary jurisdiction under section 263 in  in respect of share application money received by assessee-company. Tribunal  set aside revisionary order passed by Commissioner on ground that Assessing Officer in compliance with first revisionary order had called for details of share application money received and conducted detailed enquiry regarding same and thereafter passed reassessment order  Dismissing the appeal the Court held that   since in second round of litigation, Tribunal had found that Assessing Officer in compliance with revisionary order had conducted detailed enquiry in respect of share application money, Tribunal was justified in setting aside second revisionary order passed by Commissioner.  (AY. 2012-13)