Revisionary jurisdiction under section 263 upheld; faceless assessments subject to revision when AO fails requisite enquiries, remitted for fresh asse...
Limited scope of processing under section 143(1): enhancement without show cause is unsustainable; remand for residency, taxation and TDS verification...
Revision under section 263 was examined on whether the AO failed to make requisite enquiries or made inadequate enquiries; the tribunal found the AO had verified seized materials, recorded the assessee's statement and considered explanations, so the basis for revisional jurisdiction was absent and the PCIT's order could not be sustained. The requirement that a revisional order be founded on objective material and specific findings, not mere subjective dissatisfaction or the brevity of the AO's order, was emphasized; consequently the revisional action was quashed and the appeal allowed.
Revision under section 263 was examined on whether the AO failed to make requisite enquiries or made inadequate enquiries; the tribunal found the AO had verified seized materials, recorded the assessee's statement and considered explanations, so the basis for revisional jurisdiction was absent and the PCIT's order could not be sustained. The requirement that a revisional order be founded on objective material and specific findings, not mere subjective dissatisfaction or the brevity of the AO's order, was emphasized; consequently the revisional action was quashed and the appeal allowed.
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