https://www.taxtmi.com/caselaws?id=771032 ITAT Bangalore quashed the PCIT's revisionary order u/s 263, ruling that the underlying reassessment proceedings u/s 147 were invalid. The AO had relied on a tax evasion petition alleging unaccounted cash sales, but this information lacked evidence such as sale bills or supporting documentation. The AO failed to conduct proper enquiries before reopening assessment. ITAT found that enquiries made u/s 133(6) revealed no substance to the allegations, with transactions already recorded in books of account. Since the reassessment was based on invalid jurisdiction assumption, subsequent s 263 proceedings could not stand. The order was neither erroneous nor prejudicial to revenue interests. en-us Wed, 30 Apr 2025 00:00:00 +0530 Sat, 17 May 2025 12:43:24 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=771032 ITAT Bangalore quashed the PCIT's revisionary order u/s 263, ruling that the underlying reassessment proceedings u/s 147 were invalid. The AO had relied on a tax evasion petition alleging unaccounted cash sales, but this information lacked evidence such as sale bills or supporting documentation. The AO failed to conduct proper enquiries before reopening assessment. ITAT found that enquiries made u/s 133(6) revealed no substance to the allegations, with transactions already recorded in books of account. Since the reassessment was based on invalid jurisdiction assumption, subsequent s 263 proceedings could not stand. The order was neither erroneous nor prejudicial to revenue interests. Case-Laws Income Tax Wed, 30 Apr 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=771032