The case was reopened based on documents discovered during a search at another firm, revealing financial transactions. The Assessing Officer assessed the income, applying a G.P. rate of 19.40%. The PCIT invoked S.263, alleging that the AO failed to verify cash transactions and ordered a fresh assessment. However, the Tribunal quashed the PCIT’s order, ruling that the AO had adequately examined the issue of unaccounted cash sales during the assessment proceedings, held that the s. 263 could not be invoked merely because the PCIT had a differing view. Order of Tribunal is affirmed. (AY. 2012-13)
PCIT v. Asiatic Bearing Co [2025] 172 taxmann.com 646(Guj)(HC)
S. 263 : Commissioner-Revision of orders prejudicial to revenue-Unaccounted cash sales-Assessing Officer has examined the issue in the original assessment proceedings-Revision is not valid merely because the PCIT has a differing views-Order of Tribunal is affirmed-No substantial question of law.[S.68, 260A]
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