CIT's Section 263 Revision Upheld Due to AO's Oversight of Invoice-Duty Discrepancy; Lack of Due Diligence Noted.

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....Revision u/s 263 by CIT - there is a huge difference in invoice value and the duty paid as per the Annexure-15 and the ITS data available -reconciliation should have been sought by Ld. AO during the course of assessment proceedings. Non-seeking of such reconciliation, which apparently should have been sought, in our view, indicates non-application of mind to the given set of facts by Ld. AO during the course of assessment proceedings. - Revision order sustained - AT....