Assessment was framed making additions on account unexplained cash expenditure and unrecorded cash receipts. During assessment under section 153A read with section 143(3) pursuant to search certain specific queries were raised by Assessing Officer with respect to such cash payments made by assessee however, assessee did not turn up to tort-out any explanation. Commissioner revised the order. Tribunal held that apparently while framing assessment pursuant to search Assessing Officer missed out amount claimed to have paid by assessee as labour charges. On facts, PCIT was justified in invoking revisionary power under section 263 as order passed by Assessing Officer was erroneous and prejudicial to interest of revenue. (AY. 2014-15)
Shrigopal Rameshkumar Sales (P.) Ltd. v. ACIT (2022) 196 ITD 107 (Nagpur)(Trib.)
S. 263 : Commissioner-Revision of orders prejudicial to revenue-Search-Un explained expenditure-Cash paid to labour charges-No explanation was furnished-Revision is held to be valid. [S. 69C, 132, 153A]