The assessee, engaged in redevelopment of a building known as “Ganesh Nivas”, filed its return for A.Y. 2018-19 declaring nil income. During scrutiny, the Assessing Officer noticed that the assessee had entered into various Permanent Alternate Accommodation Agreements with existing tenants, having cumulative Stamp Duty Value of ₹4.24 crore. The assessee explained that the agreements were executed to allot the existing tenants area in lieu of their existing area, free of cost, and that no consideration was received from them. As the assessee failed to respond to the show-cause notices, the Assessing Officer completed the assessment under section 143(3) read with section 144B by adding ₹4.24 crore as unexplained investment under section 69. The assessee filed a revision application under section 264 and contended that the transactions were PAAA’s with existing tenants and not sales of immovable properties. Before the Revisional Authority, however, the assessee produced only Index-II and did not produce the PAAA’s, permission from MHADA or other supporting evidence. The Revisional Authority dismissed the revision application for want of supporting evidence. The Bombay High Court observed that, merely on the basis of Index-II, the Revisional Authority could not be faulted for rejecting the application; however, considering the assessee’s submission that it possessed the necessary evidence to substantiate its claim, the Court held that the interest of justice would be served by permitting the assessee to place all relevant material before the Revisional Authority. The impugned revisional order was accordingly directed to be quashed and the matter restored to the Revisional Authority, subject to payment of ₹1 lakh as costs, with a direction to examine the evidence and pass a fresh order under section 264 after granting an opportunity of hearing. The Court clarified that the order was passed in the peculiar facts of the case, was not to be treated as a precedent, and that it had not examined the merits of the assessee’s contentions. (AY. 2018-19) (Writ Petition No. 3645 of 2024 dt. 27-07-2026)