PCIT v. Asiatic Bearing Co. (2025) 304 Taxman 533 (Guj.)(HC)

S. 263 : Commissioner-Revision of orders prejudicial to revenue –
Unexplained investments-Unaccounted cash sales-Assessing Officer had duly examined issue of unaccounted cash sales during assessment proceedings -Order of Tribunal quashing the revision order passed by the Commissioner is affirmed. [S.69C 143(3), 260A, 263, Explanation 2.]

The assessment was reopened based on documents found during search at certain firm, revealing financial transactions. Assessing Officer assessed income, adding using G.P. rate of 19.40%. PCIT invoked Section 263, arguing that Assessing Officer failed to verify cash transactions and ordered fresh assessment. Tribunal quashed PCIT’s order, holding that Assessing Officer had duly examined issue of unaccounted cash sales during assessment proceedings. High Court affirmed the order of Tribunal holding that  Tribunal had rightly held that PCIT had erred in invoking provisions of section 263 and had rightly set aside said order. (AY. 2012-13)

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