RBS Credit And Financial Development P. Ltd. v. CIT (2018) 63 ITR 20 (SN) (Kol)( Trib)

S. 263 : Commissioner – Revision of orders prejudicial to revenue – Cash credits -Share application money -Details were filed in the original assessment proceedings -AO is not to be expected to discuss each and every item of verification in assessment order- Revision is held to be not justified .[ S.143(3)]

Allowing the appeal of the assessee the Tribunal held that the AO has called the details and after verification no disallowance was made . Accordingly there was no occasion for him to discuss about the same in the assessment order. Merely because there was no mention regarding this issue in the assessment order, it could not be presumed that the Assessing Officer had not made any enquiry in this regard in the assessment proceedings. The Assessing Officer could not be expected to discuss each and every item of his verification in the assessment order and was expected to address only those issues on which he was not in agreement with the assessee, in his assessment order.. Therefore the order passed by the Assessing Officer could not be termed erroneous inasmuch as it was prejudicial to the interests of the Revenue, warranting revision under section 263 in the facts and circumstances of the case. ( AY.2012-13)