CIT's Section 263 Revision Lacks Independent Investigation, Relies on JCIT Letter; Lacks Guidance for Further AO Enquiry.

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....Revision u/s 263 by CIT - reopening on the basis of letter written by JCIT - In the case in hand the Ld. Revisional Authority has done no homework on its end but merely on basis of letter of JCIT pointing short comings, held that enquiry done by Ld. AO was not satisfactory. Infact where the Revisional Authority intends to set aside assessment order for lack of enquiry the direction in the order exercise of Revisional power should set or indicate the possible and prospective path of enquiry that the AO should follow further. Which is also not done in present case. - AT....