https://www.taxtmi.com/caselaws?id=762538 ITAT Delhi upheld CIT's revision order under section 263, finding the assessment order erroneous and prejudicial to revenue. The AO failed to examine discrepancies between 26AS receipts (Rs. 5,71,044) and ITR receipts (Rs. 2,22,540) from aviation companies, and did not investigate demat and bank account transactions. ITAT held that section 263 applies when necessary inquiries are not made, using an objective test. The assessee could not demonstrate that proper examinations were conducted, failing to establish this was merely a change of opinion. The revision was deemed justified as the AO should have made adequate inquiries to reach logical conclusions. en-us Fri, 29 Nov 2024 00:00:00 +0530 Tue, 03 Dec 2024 08:44:56 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=762538 ITAT Delhi upheld CIT's revision order under section 263, finding the assessment order erroneous and prejudicial to revenue. The AO failed to examine discrepancies between 26AS receipts (Rs. 5,71,044) and ITR receipts (Rs. 2,22,540) from aviation companies, and did not investigate demat and bank account transactions. ITAT held that section 263 applies when necessary inquiries are not made, using an objective test. The assessee could not demonstrate that proper examinations were conducted, failing to establish this was merely a change of opinion. The revision was deemed justified as the AO should have made adequate inquiries to reach logical conclusions. Case-Laws Income Tax Fri, 29 Nov 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=762538