Section 263 revision barred when assessment follows enquiry and adopts a plausible view on cash sales and deposits.

Revision under section 263 is not justified where the Assessing Officer has conducted enquiry, examined cash sales, cash deposits, stock, purchases and supporting records, and then adopted a plausible view. The absence of elaborate discussion in the assessment order does not by itself show lack of enquiry. Section 263 cannot be used to substitute a different opinion merely because the Principal Commissioner considers the enquiry inadequate or prefers another view on the same material. On these facts, the revisionary order was quashed and the assessee succeeded.

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Issues: Whether revision under section 263 of the Income-tax Act, 1961 was justified where the Assessing Officer had made enquiries on cash sales and cash deposits, examined the relevant material, and adopted one of the possible views.

Analysis: The record showed that the assessee had responded to the assessment queries relating to cash sales, cash deposits, stock position, purchases, and supporting records. The assessment order had been passed after enquiry and verification, and the revision order proceeded on the view that the inquiry was inadequate and that the deposits ought to have been assessed differently. Since the Assessing Officer had taken a plausible view after making relevant enquiries, the mere absence of detailed discussion in the assessment order did not establish lack of enquiry. A revisionary jurisdiction under section 263 could not be exercised to substitute a different opinion for a view already taken on the basis of enquiry.

Conclusion: The invocation of section 263 was not sustainable and the revisionary order was quashed in favour of the assessee.

Ratio Decidendi: Where the Assessing Officer conducts enquiry and adopts one of two possible views, the order cannot be revised under section 263 merely because the Principal Commissioner prefers a different view.

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