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ITAT dismissed the taxpayer's appeal against revision under section 263, upholding the PCIT's order. The tribunal found that the assessing officer (Ld. AO) had not demonstrated any application of mind to the treatment of "retention money," which the taxpayer had explained was not debited to profit and loss but adjusted in the income computation. The PCIT correctly noted absence of enquiry, verification or discussion in the assessment order regarding the retention money issue. Given the lack of cogent factual or legal analysis by the AO and the recorded failure of inquiry, the ITAT held the revision to be valid and found no merit in the taxpayer's contention that the PCIT's jurisdictional exercise was improper.
ITAT dismissed the taxpayer's appeal against revision under section 263, upholding the PCIT's order. The tribunal found that the assessing officer (Ld. AO) had not demonstrated any application of mind to the treatment of "retention money," which the taxpayer had explained was not debited to profit and loss but adjusted in the income computation. The PCIT correctly noted absence of enquiry, verification or discussion in the assessment order regarding the retention money issue. Given the lack of cogent factual or legal analysis by the AO and the recorded failure of inquiry, the ITAT held the revision to be valid and found no merit in the taxpayer's contention that the PCIT's jurisdictional exercise was improper.
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