Held that the revision order is passed on the basis of objection by the audit wing of the department, there was no independent application of mind by the Ld. PCIT. The A.O. in the original assessment proceedings wherein the assessee had filed three replies. Therefore, the whole contention of the Ld. PCIT that there was no application of mind by the A.O. falls. Order of revision was quashed, relied on CIT v. Sohana Woolen Mills. (AY. 2015-16)
Surinder Pal Singh v. PCIT (2022) 94 ITR 458 (Chd.)(Trib.)
S. 263 : Commissioner-Revision of orders prejudicial to revenue-Agricultural income-Mere audit objection or merely because another view is possible does not allow jurisdiction under the section, to claim the order of the AO as erroneous and prejudicial to the interests of the Revenue.