Tribunal Upholds Commissioner's Revision; Assessee's Appeal Dismissed Due to Inadequate Inquiry by Assessing Officer.

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....The assessee's appeal against the Commissioner's revision order u/s 263 was dismissed. The Tribunal held that the Assessing Officer (AO), after reopening the assessment u/s 147, failed to conduct a detailed inquiry and verification regarding the reasons for reopening and the genuineness of the transactions. The order passed u/s 147 read with Section 144B lacked findings on these aspects, rendering it erroneous and prejudicial to the Revenue's interests. The Tribunal rejected the contentions regarding non-application of mind by the Commissioner and the invalidity of the order u/s 147 due to non-addition of income. It held that the AO can make additions on other issues even if no addition is made for the reasons for reopening, and the order u.........