Reopening Assessments invalid where satisfaction and jurisdictional approval are absent for third party seized material, leading to quashing of assess...
Benami property exclusion from the insolvency estate: Benami Act proceedings preclude IBC tribunals from reopening attachments or treating such assets...
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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