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The Appellate Tribunal dismissed the assessee's appeal regarding the revision u/s 263 concerning unsecured loans received. The Principal Commissioner found that the Assessing Officer did not properly verify the unsecured loans, and the assessee failed to provide relevant documents for verification. The Tribunal held that the Assessing Officer's addition of 10% of the unsecured loan lacked basis and application of mind u/s 68. However, the revisional order pertained to the remaining unverified unsecured loan creditors, where the Assessing Officer erred by not conducting proper verification, prejudicing revenue interests. Mere document submission did not satisfy Section 263 requirements. The assessee's reliance on a distinguishable case was rejected, as the issue of verification remained unaddressed by the Assessing Officer in the impugned assessment.
The Appellate Tribunal dismissed the assessee's appeal regarding the revision u/s 263 concerning unsecured loans received. The Principal Commissioner found that the Assessing Officer did not properly verify the unsecured loans, and the assessee failed to provide relevant documents for verification. The Tribunal held that the Assessing Officer's addition of 10% of the unsecured loan lacked basis and application of mind u/s 68. However, the revisional order pertained to the remaining unverified unsecured loan creditors, where the Assessing Officer erred by not conducting proper verification, prejudicing revenue interests. Mere document submission did not satisfy Section 263 requirements. The assessee's reliance on a distinguishable case was rejected, as the issue of verification remained unaddressed by the Assessing Officer in the impugned assessment.
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