The AO had raised queries on the drop of gross profit and the assessee had submitted requisite information/details along with explanation. The AO accepted the explanation being satisfied with the explanation.  Tribunal held that such a decision cannot be held to be erroneous simply because in his assessment order the AO did not make any elaborate discussion in that regard. Moreover, the Commissioner himself, even after initiating proceedings in revision and hearing the assessee, has simply said submissions made by the assessee are considered but the same is not acceptable. The Commissioner has not given any detailed explanation why the explanation of the assessee was not acceptable. Without coming to such conclusion or discussing why assessee’s explanation was not acceptable, the Commissioner cannot simply ask the AO to conduct enquiries/fresh determination.  On appeal by the Revenue the Court  held  that Tribunal has not committed any perversity or applied incorrect principles to the given facts and when the facts and circumstances are properly analysed and correct test is applied to decide the issue at hand. Order of Tribunal is affirmed.  (ITA No. 1838/2017 dt  3-3-2022).

PCIT  v. Rajhans Metal Pvt. Ltd. (Bom.)(HC)(UR)