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Assessing Officer conducted due enquiries regarding cash deposits during demonetization period, called for details from assessee to substantiate source. AO applied mind, accepted assessee's submissions after receiving replies. Not a case of no enquiry or lack of enquiry. AO made expected enquiries, accepted source of cash deposits after notices to assessee. Order prejudicial to Revenue but not erroneous considering enquiries. CIT did not examine details himself, merely set aside matter for fresh assessment without further enquiries. Decisions support proposition that where AO conducted enquiries on demonetization cash deposits and took possible view, CIT not justified invoking revision u/s 263 by directing fresh enquiry without conducting further enquiries himself. AO made detailed enquiries, took possible view, hence CIT not justified invoking section 263. Order set aside, assessee's grounds allowed.
Assessing Officer conducted due enquiries regarding cash deposits during demonetization period, called for details from assessee to substantiate source. AO applied mind, accepted assessee's submissions after receiving replies. Not a case of no enquiry or lack of enquiry. AO made expected enquiries, accepted source of cash deposits after notices to assessee. Order prejudicial to Revenue but not erroneous considering enquiries. CIT did not examine details himself, merely set aside matter for fresh assessment without further enquiries. Decisions support proposition that where AO conducted enquiries on demonetization cash deposits and took possible view, CIT not justified invoking revision u/s 263 by directing fresh enquiry without conducting further enquiries himself. AO made detailed enquiries, took possible view, hence CIT not justified invoking section 263. Order set aside, assessee's grounds allowed.
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