Section 263 revision cannot replace a reasoned profit-estimation assessment after enquiry into disputed purchases and sales.

Revision under section 263 was not justified where the Assessing Officer had conducted enquiries into the impugned purchase and sale transactions, examined invoices, bank records, transport details and GST particulars, rejected the books under section 145(3), and adopted a profit-estimation approach. The record showed a reasoned assessment based on a possible view of the matter in a case involving alleged non-genuine purchases and sales. Because enquiry had in fact been made, the matter was not one of complete lack of enquiry, and the revisionary authority could not substitute its own view by making substantive additions and penal consequences.

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Issues: Whether revision under section 263 was justified when the Assessing Officer had examined the impugned purchase and sale transactions, rejected the books under section 145(3), and adopted a profit-estimation approach on a possible view of the matter.

Analysis: The assessment record showed repeated notices, requisitions, and replies on the genuineness of the transactions, including verification of parties, invoices, bank records, transportation details, and GST-related particulars. The Assessing Officer thereafter rejected the books and estimated gross profit on the disputed transactions. The revisionary authority sought to substitute that approach with substantive additions and penal consequences, treating the assessment as erroneous and prejudicial to the Revenue. However, the material on record showed that enquiry was in fact conducted and the Assessing Officer had taken a reasoned view on estimation of profit in a case involving alleged non-genuine purchases and sales. In such circumstances, the case fell within the category of enquiry made, even if another view was possible, and not a case of complete absence of enquiry.

Conclusion: Revision under section 263 was not justified, as the Assessing Officer's view was a possible view reached after due enquiry.

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