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HC held that PCIT validly exercised revisional jurisdiction under Section 263 by setting aside the AO's assessment order. The order was found erroneous due to lack of verification of sundry creditors' transactions, with one of 70 entries confirmed as bogus. The DCIT's recommendation and PCIT's subsequent action were deemed proper, as the AO failed to conduct requisite inquiries. The ITAT's earlier rejection was deemed without merit. The time limit under Section 153 does not apply to assessments directed under Section 263. Ultimately, the decision was rendered in favor of the revenue, mandating comprehensive examination of the disputed transactions and ensuring procedural compliance.
HC held that PCIT validly exercised revisional jurisdiction under Section 263 by setting aside the AO's assessment order. The order was found erroneous due to lack of verification of sundry creditors' transactions, with one of 70 entries confirmed as bogus. The DCIT's recommendation and PCIT's subsequent action were deemed proper, as the AO failed to conduct requisite inquiries. The ITAT's earlier rejection was deemed without merit. The time limit under Section 153 does not apply to assessments directed under Section 263. Ultimately, the decision was rendered in favor of the revenue, mandating comprehensive examination of the disputed transactions and ensuring procedural compliance.
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