https://www.taxtmi.com/caselaws?id=457997 ITAT Rajkot upheld PCIT's revision order u/s 263 finding assessment erroneous and prejudicial to revenue. Case involved reopening u/s 147 for huge cash deposits where assessee provided contradictory explanations - one attributing deposits to third party, another claiming business transactions. AO failed to conduct necessary inquiries despite conflicting submissions and accepted one explanation without reasoning. ITAT confirmed assessment lacked application of mind and proper investigation. Assessee's argument that pending appeal before CIT(A) barred revision powers was rejected citing Supreme Court precedent that assessment order subsists during appeal pendency. Appeals dismissed. en-us Wed, 10 Apr 2024 00:00:00 +0530 Thu, 03 Oct 2024 05:25:46 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=457997 ITAT Rajkot upheld PCIT's revision order u/s 263 finding assessment erroneous and prejudicial to revenue. Case involved reopening u/s 147 for huge cash deposits where assessee provided contradictory explanations - one attributing deposits to third party, another claiming business transactions. AO failed to conduct necessary inquiries despite conflicting submissions and accepted one explanation without reasoning. ITAT confirmed assessment lacked application of mind and proper investigation. Assessee's argument that pending appeal before CIT(A) barred revision powers was rejected citing Supreme Court precedent that assessment order subsists during appeal pendency. Appeals dismissed. Case-Laws Income Tax Wed, 10 Apr 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=457997