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ITAT quashed revisionary proceedings under section 263 initiated by PCIT regarding unexplained cash deposits. While assessee had deposited Rs. 16 lacs in multiple transactions of Rs. 25,000 each, these amounts originated from opening cash balance pertaining to AY 2012-13. During reassessment under section 147, AO had conducted proper inquiries and obtained necessary explanations from assessee regarding bank deposits. ITAT held that since AO had taken a plausible view after due application of mind and specific verification, PCIT's revision order alleging non-application of mind was not sustainable. The tribunal emphasized that department could separately initiate proceedings under section 147 for AY 2012-13 if income had escaped assessment for that year.
ITAT quashed revisionary proceedings under section 263 initiated by PCIT regarding unexplained cash deposits. While assessee had deposited Rs. 16 lacs in multiple transactions of Rs. 25,000 each, these amounts originated from opening cash balance pertaining to AY 2012-13. During reassessment under section 147, AO had conducted proper inquiries and obtained necessary explanations from assessee regarding bank deposits. ITAT held that since AO had taken a plausible view after due application of mind and specific verification, PCIT's revision order alleging non-application of mind was not sustainable. The tribunal emphasized that department could separately initiate proceedings under section 147 for AY 2012-13 if income had escaped assessment for that year.
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