https://www.taxtmi.com/caselaws?id=445010 ITAT Delhi set aside CIT's revision order under Section 263 regarding cash advance transactions. The court held that CIT cannot merely set aside assessment based on new facts without proper inquiry or speaking order. CIT failed to consider assessee's response and evidence, making summary observations without discussion. The revision order suffered from apparent error and incompleteness, violating natural justice principles. CIT improperly shifted responsibility to AO without discharging quasi-judicial functions reasonably. The opportunity under Section 263 became illusory formality causing miscarriage of justice. Decision favored assessee. en-us Mon, 16 Oct 2023 00:00:00 +0530 Fri, 27 Oct 2023 12:41:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=445010 ITAT Delhi set aside CIT's revision order under Section 263 regarding cash advance transactions. The court held that CIT cannot merely set aside assessment based on new facts without proper inquiry or speaking order. CIT failed to consider assessee's response and evidence, making summary observations without discussion. The revision order suffered from apparent error and incompleteness, violating natural justice principles. CIT improperly shifted responsibility to AO without discharging quasi-judicial functions reasonably. The opportunity under Section 263 became illusory formality causing miscarriage of justice. Decision favored assessee. Case-Laws Income Tax Mon, 16 Oct 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=445010