Rudra Developers v. PCIT (2021) 213 TTJ 715 (Surat)(Trib.)

S. 263 : Commissioner-Revision of orders prejudicial to revenue-Additional income disclosed in the course of survey-Land development expenses-Revision order is held to be not valid. [S. 133A]

Tribunal held that the assessee had submitted all the necessary documents and explanations which was accepted by the ld. AO after due application of mind and verification.  AO worked as an adjudicator as well as an investigator and therefore the order under section 143(3) was not erroneous. Tribunal also observed that the ld. PCIT’s contentions were merely based on suspicion and conjecture. As a result, the impugned proceeding was quashed. (AY. 2014-15)