Revision of assessment sustained where unexplained bank deposits were directed to be taxed as income from other sources.

In revisionary proceedings, a Principal Commissioner may sustain revision where the assessee fails to show that the Assessing Officer examined the issue and adopted a possible view, or that the revised view is unsustainable. On the facts stated, the assessee did not establish that the assessment treatment of unexplained bank deposits as business income had been properly examined by the Assessing Officer. The record also did not show that the Principal Commissioner's view that the order was erroneous and prejudicial to the interests of Revenue was untenable. The revision order directing assessment of the deposits under the head "income from other sources" was therefore upheld.

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Issues: Whether the revision order directing that unexplained bank deposits be assessed under the head "income from other sources" in place of "business income" was valid.

Analysis: The assessee did not produce material to show that the Assessing Officer had examined the issue and adopted a possible view. The record also did not establish that the Principal Commissioner's view that the assessment order was erroneous and prejudicial to the interests of Revenue was unsustainable.

Conclusion: The revision order was upheld and the assessee's challenge was rejected.

Final Conclusion: The assessment treatment of the unexplained bank deposits as business income did not survive, and the Principal Commissioner's direction to assess the amount under the head "income from other sources" stood confirmed.

Ratio Decidendi: In revisionary proceedings, where the assessee fails to show that the Assessing Officer examined the issue or that the revised view is unsustainable, the order may be sustained as erroneous and prejudicial to the interests of Revenue.

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