Reassessment proceedings were initiated to examine alleged accommodation loans. The assessee consistently denied having received any such loans and produced its audited books of account, bank statements and ledger accounts demonstrating that no such transactions existed. The Assessing Officer completed the reassessment without making any addition. The Principal Commissioner revised the reassessment order under section 263 directing further enquiry into the alleged loans. The Tribunal held that neither the Assessing Officer nor the Principal Commissioner found any entry in the books or bank statements evidencing the alleged accommodation entries. Once the assessee had produced all relevant records, the burden shifted to the Revenue to establish receipt of the alleged loans. Revision based merely on suspicion, without any tangible material, was unsustainable and the order under section 263 was quashed.

(AY. 2017-18).