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HC dismissed writ petitions challenging revision proceedings u/s 263 as not entertainable, following precedent in Piyara Lal case. PCIT validly initiated revision after finding AO completed assessment u/s 143(3) without proper verification of asset valuation discrepancies, purchase value differences, and post-demonetization cash deposits requiring examination per SOP guidelines. Court declined merits examination, directing petitioners to pursue statutory remedies by filing objections within four weeks, with subsequent appeal rights to Tribunal if adverse orders passed. Respondents must consider objections on merits and decide notices in accordance with law.
HC dismissed writ petitions challenging revision proceedings u/s 263 as not entertainable, following precedent in Piyara Lal case. PCIT validly initiated revision after finding AO completed assessment u/s 143(3) without proper verification of asset valuation discrepancies, purchase value differences, and post-demonetization cash deposits requiring examination per SOP guidelines. Court declined merits examination, directing petitioners to pursue statutory remedies by filing objections within four weeks, with subsequent appeal rights to Tribunal if adverse orders passed. Respondents must consider objections on merits and decide notices in accordance with law.
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