Court overturns CIT's revision orders challenging income tax assessment for 2006-07 and 2007-08.

The court set aside the revision orders by the Commissioner of Income Tax (CIT) challenging the initiation of revision proceedings under section 263 of the Income-tax Act for the assessment years 2006-07 and 2007-08. The assessing officer's estimation of income based on gross receipts was deemed reasonable, considering the lack of proper books of accounts. The CIT's direction to determine income from godown receipts separately was overturned, and the assessing officer's proposed enhancement of the estimate was upheld. Consequently, the appeals of the assessee were allowed.

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Issues involved: Challenge to the validity of initiation of revision proceedings u/s 263 of the Income-tax Act by Ld. CIT.

Summary:
The appeals were filed by the assessee challenging the orders passed by Ld. CIT u/s 263 of the Income-tax Act for the assessment years 2006-07 and 2007-08. The assessing officer estimated income at 10% of the gross receipts after necessary inquiries. Ld. CIT initiated revision proceedings u/s 263, stating that the methodology resulted in underestimation of total income. The Ld. CIT directed to re-do the assessments by determining income from godown receipts separately. The assessee argued that assessments were completed based on estimates due to lack of proper books of accounts. The assessing officer considered all aspects and proposed to enhance the estimate. The assessing officer's view was deemed plausible, and the revision orders by Ld. CIT were set aside for both years. The assessing officer's actions were considered reasonable, and the appeals of the assessee were allowed.

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