2025 (4) TMI 1137

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....HON'BLE MR. JUSTICE SANJAY KUMAR And HON'BLE MR. JUSTICE K.V. VISWANATHAN For the Petitioner : Mr. S Dwarakanath, A.S.G. Mr. Rupesh Kumar, Sr. Adv. Mr. Raj Bahadur Yadav, AOR Mr. Anmol Chandan, Adv. Mr. Kartikeya Asthana, Adv. Mr. Rajeev Kumar Ranjan, Adv. ORDER UPON hearing the counsel, the Court made the following. Delay condoned. In our opinion, the order passed by the Hi....

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....nd, recording that there was failure to investigate. There is a distinction between the failure or absence of investigation and a wrong decision/conclusion. A wrong decision/conclusion can be corrected by the Commissioner of Income Tax with a decision on merits and by making an addition or disallowance. There may be cases where the Assessing Officer undertakes a superficial and random investiga....