https://www.taxtmi.com/caselaws?id=447292 The ITAT Rajkot quashed the PCIT's revision order under Section 263, finding that the AO had conducted adequate inquiries regarding cash deposits during demonetization. The tribunal noted that SFT returns under Section 285BA contained complete transaction details with names and addresses, and the AO had issued proper notices under Section 142(1) which were duly complied with by the assessee. Crucially, bank statements revealed no cash transactions in the HDFC account during the relevant period, with all transactions conducted through cheque or NEFT. The PCIT's revision was based on incorrect factual assumptions and failed to consider the assessee's complete response. The tribunal emphasized that both ingredients - an erroneous order prejudicial to revenue interests - must be present for valid Section 263 proceedings, citing Malabar Industrial Co. Ltd. The appeal was allowed. en-us Wed, 20 Dec 2023 00:00:00 +0530 Fri, 22 Dec 2023 09:42:20 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=447292 The ITAT Rajkot quashed the PCIT's revision order under Section 263, finding that the AO had conducted adequate inquiries regarding cash deposits during demonetization. The tribunal noted that SFT returns under Section 285BA contained complete transaction details with names and addresses, and the AO had issued proper notices under Section 142(1) which were duly complied with by the assessee. Crucially, bank statements revealed no cash transactions in the HDFC account during the relevant period, with all transactions conducted through cheque or NEFT. The PCIT's revision was based on incorrect factual assumptions and failed to consider the assessee's complete response. The tribunal emphasized that both ingredients - an erroneous order prejudicial to revenue interests - must be present for valid Section 263 proceedings, citing Malabar Industrial Co. Ltd. The appeal was allowed. Case-Laws Income Tax Wed, 20 Dec 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=447292