Shree Maruti Nandan Guwar Gum (P) Ltd. v. PCIT (2021) 213 TTJ 65 (UO) (Jodhpur)(Trib.)

S. 263 : Commissioner-Revision of orders prejudicial to revenue-Explanation was submitted on various issues during the course of assessment proceedings-Revision order was quashed.

Tribunal held that various issues were duly examined during the course of assessment proceedings. The power of revision of orders passed by the AO u/s. 263 of the Act is in the nature of supervisory jurisdiction which is permissible to be exercised only when the twin conditions are satisfied that the order passed by the AO is erroneous and further on account of order being erroneous, prejudice has been caused to the interest of revenue. The record of the assessment proceedings was not examined by the Principal CIT in its entirety and objectivity.  The order u/s 263 cannot be sustained as the assessment order passed by the AO cannot be said to be erroneous or prejudicial to the interest of revenue, and accordingly the order made u/s 263 is quashed. (AY. 2012-13)