Ravinder Bawa (Smt.) v. ITO (2022) 98 ITR 149 (Amritsar) (Trib)

S. 263 : Commissioner-Revision of orders prejudicial to revenue-Assessing Officer made complete enquiries-No adverse comments made by investigation department-Failure to bring evidence of cash deposited in account by Principal Commissioner-Proceedings without any merit-Revision order was quashed. [S. 147, 148]

Held, that the Principal Commissioner had failed to bring on record the material or evidence which showed that the assessee had deposited the cash in her bank account. The Principal Commissioner had failed to establish the fulfilment of twin conditions before invoking the jurisdiction under section 263 of the Act and failed to bring on record how the order passed by the Assessing Officer was prejudicial to the interests of the Revenue and further how it was erroneous. Hence, the action initiated under section 263 was without any merit and it was quashed. (AY. 2011-12).