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ITAT upheld revision proceedings under s.263 concerning genuineness of sundry creditors. AO initially questioned transactions with 10 creditors but made additions under s.41(1) for only 2 parties, failing to examine remaining 8 creditors without justification. Assessee's non-compliance in furnishing requisite details during assessment and discrepancy in ledger account of AJS Impex Pvt Ltd (showing credit balance contrary to noted debit balance) demonstrated inadequate verification. Order under s.143(3) r.w.s. 144B deemed erroneous as it lacked comprehensive inquiry mandated by Explanation 2 to s.263. AO's selective treatment of similar transactions without reasoned basis constituted jurisdictional error warranting revision.
ITAT upheld revision proceedings under s.263 concerning genuineness of sundry creditors. AO initially questioned transactions with 10 creditors but made additions under s.41(1) for only 2 parties, failing to examine remaining 8 creditors without justification. Assessee's non-compliance in furnishing requisite details during assessment and discrepancy in ledger account of AJS Impex Pvt Ltd (showing credit balance contrary to noted debit balance) demonstrated inadequate verification. Order under s.143(3) r.w.s. 144B deemed erroneous as it lacked comprehensive inquiry mandated by Explanation 2 to s.263. AO's selective treatment of similar transactions without reasoned basis constituted jurisdictional error warranting revision.
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