How many judgments cite CIT v. Sunbeam Auto Ltd.?

897 judgments on BharatTax cite CIT v. Sunbeam Auto Ltd. (332 ITR 167), spanning 2011 to 2026.

Which sections of the Income Tax Act does CIT v. Sunbeam Auto Ltd. come up under?

It is most often cited in judgments turning on Section 263, Section 143(3), Section 142(1), Section 57(iv), Section 56(2)(viii), Section 10(37).

CIT v. Sunbeam Auto Ltd.

332 ITR 167High Court2011#54 most cited

What is CIT v. Sunbeam Auto Ltd. authority for?

The Commissioner cannot revise an assessment under Section 263 merely because the assessment order does not explicitly reflect an inquiry, or because the Commissioner holds a different opinion. An inquiry, even if considered inadequate, or an assessment based on a plausible view by the Assessing Officer after due examination, does not automatically make the order erroneous or prejudicial to the interests of the revenue.

897

judgments rely on this decision, according to BharatTax’s citation analysis of 367,514 Indian tax judgments — from 2011 to 2026.

Also referred to as

CIT v. Sunbeam Auto Ltd. · Sunbeam Auto Ltd. · Section 263 · Commissioner revisionary powers · lack of enquiry · inadequate enquiry · plausible view AO · not prejudicial to revenue · assessment order detail · different opinion Commissioner · 143(3) scrutiny assessment

Also reported as

189 Taxmann 436227 CTR 13331 DTR 189 Taxmann.com 191

Sections most often in play

Section 263 Section 143(3)Section 142(1)Section 57(iv)Section 56(2)(viii)Section 10(37)Section 143(2)Section 147

Read the full judgment

Issues it is cited on

section 145b section 45(5)section 145a(b)section 57(iv)inadequate enquiry section 56(2)(viii)lack of enquiry section 10(37)enhanced compensation malabar industrial section 263(1)section 145a

Judgments citing CIT v. Sunbeam Auto Ltd.

Kharak Singh, Noida vs. ITO Ward 1(1), Noida

In the result, appeal of the assessee is allowed

ITA 775/DEL/2025[2014-15]Status: HeardITAT Delhi26 May 2025AY 2014-15

Bench: Shri Satbeer Singh Godara

Section 10(37)Section 142(1)Section 143Section 143(1)(a)Section 143(2)Section 143(3)Section 147Section 263Section 28Section 56(2)(viii)

…ely because in his order the Ld. AO did not make elaborate discussion but was satisfied with the explanation of the assessee, the order could not be held to be erroneous. In support the decisions of Hon'ble Delhi High Court in CIT vs. Sunbeam Auto Ltd. (2011) 332 ITR 167 (Del) and decision of Hon'ble Rajasthan High Court in CIT vs. Ganpat Ram Bisnoi 296 ITR 292 (Raj.) were cited. 6.2 The Ld. AR invited our attention to Audit Memo at pages 399-402 of Paper Book in the case of the assessee wherein ITO (Audit) Hisar raised an audit objection observing that interest under section 28 of Land Acquisition Act of Rs. 3,9…

Chander Bhan, Hansi vs. Income-Tax Officer, Hisar

In the result, appeal of the assessee is allowed

ITA 4112/DEL/2024[2017-18]Status: DisposedITAT Delhi26 May 2025AY 2017-18

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwalassessment Year: 2017-18 Sh. Chander Bhan, Vs. Income Tax Officer, H. No. 566/14, Jind Road, Ward-1, Hisar, Saniyan Mohalla, Haryana Hansi Distt., Hisar, Haryana Pan: Ayypb8380N (Appellant) (Respondent) Assessee By Sh. Lalit Mohan, Ca Department By Sh. Rajesh Kumar Dhanesta, Sr. Dr

Section 10(37)Section 142(1)Section 143Section 143(1)(a)Section 143(2)Section 143(3)Section 147Section 263Section 28Section 56(2)(viii)

…ely because in his order the Ld. AO did not make elaborate discussion but was satisfied with the explanation of the assessee, the order could not be held to be erroneous. In support the decisions of Hon'ble Delhi High Court in CIT vs. Sunbeam Auto Ltd. (2011) 332 ITR 167 (Del) and decision of Hon'ble Rajasthan High Court in CIT vs. Ganpat Ram Bisnoi 296 ITR 292 (Raj.) were cited. 6.2 The Ld. AR invited our attention to Audit Memo at pages 399- 402 of Paper Book in the case of the assessee wherein ITO (Audit) Hisar raised an audit objection observing that interest under section 28 of Land Acquisition Act of Rs. 3,…

Nature Commercial Pvt Ltd, Delhi vs. ITO, Ward-2(1), Kolkata

In the result, appeal of the assessee stands allowed

ITA 853/KOL/2024[2008-09]Status: DisposedITAT Kolkata22 May 2025AY 2008-09

Bench: Shri Rajesh Kumar, Am& Shri Pradip Kumar Choubey, Jm]

Section 131Section 133(6)Section 142(1)Section 143(3)Section 147Section 148Section 250Section 263Section 68

…IN THE INCOME TAX APPELLATE TRIBUNAL “B” BENCH, KOLKATA [Before Shri Rajesh Kumar, AM& Shri Pradip Kumar Choubey, JM] I.T.A. No. 853/Kol/2024 Assessment Year: 2008-09 M/s Nature Commercial Pvt. Ltd. H. No. 175, Ground Floor, Gali No. 4, Near Shamsham Bhumi, East Delhi- 110032. (PAN: AACCN6158K) Appellant Vs. ITO, Ward-2(1), Kolkata. Respondent Date of conclusion of Hearing 14.05.2025 Date of Pronouncement 22.05.2025 For the Appellant Shri Soumitra Choudhury & Shri Pranabesh Sarkar, Advocates For the Respondent Shri P. N. Barnwal, CIT DR ORDER Per Shri Rajesh Kumar, AM The appeal filed by the assessee is against…

Subhash Chander, Hisar vs. Principal Commissioner of Income Tax, Rohtak

In the result, appeal of the assessee is allowed

ITA 2356/DEL/2024[2019-20]Status: DisposedITAT Delhi21 May 2025AY 2019-20

Bench: Sh. Satbeer Singh Godara & Sh. S. Rifaur Rahmanita No. 2356/Del/2024 : Asstt. Year : 2019-20 Subhash Chander, Vs Pcit, House No. 1476, Vivek Nagar, Rohtak, Hisar, Haryana-125001 Haryana-124001 (Appellant) (Respondent) Pan No. Axlpc0177G Assessee By : Sh. Kuldip Khera, Ca Revenue By : Sh. Jitender Singh, Cit-Dr Date Of Hearing: 21.05.2025 Date Of Pronouncement: 21.05.2025 Order Per Satbeer Singh Godara: This Assessee’S Appeal For Assessment Year 2019-20, Arises Against The Pcit, Rohtak’S Din & Order No. Itba/Rev/F/Rev5/2023–24/1062890142(1) Dated 19.03.2024, In Proceedings U/S 143(3) Of The Income Tax Act, 1961 (In Short “The Act”).

For Appellant: Sh. Kuldip Khera, CAFor Respondent: Sh. Jitender Singh, CIT-DR

Section 10(37)Section 142(1)Section 143Section 143(1)(a)Section 143(2)Section 143(3)Section 263Section 28Section 56(2)(viii)Section 57

…ely because in his order the Ld. AO did not make elaborate discussion but was satisfied with the explanation of the assessee, the order could not be held to be erroneous. In support the decisions of Hon'ble Delhi High Court in CIT vs. Sunbeam Auto Ltd. (2011) 332 ITR 167 (Del) and decision of Hon'ble Rajasthan High Court in CIT vs. Ganpat Ram Bisnoi 296 ITR 292 (Raj.) were cited. 4 Subhash Chander 6.2 The Ld. AR invited our attention to Audit Memo at pages 399-402 of Paper Book in the case of the assessee wherein ITO (Audit) Hisar raised an audit objection observing that interest under section 28 of Land Acquisi…

Pr.Commissioner of Income Tax(Central)2 vs. Delhi Gurgaon Super Connectivity Ltd. & Anr

The appeal is allowed in favour of the

ITA/424/2022HC Delhi13 May 2025

Bench: CASES PERTAINING TO SPL.DIVISION BENCHES

For Appellant: Mr. Indruj Singh Rai, SSC with Mr. SanjeevFor Respondent: Dr. Rakesh Gupta, Mr. Somil Agarwal and

Section 141(2)Section 143(2)Section 144Section 156Section 260ASection 271Section 271(1)(b)Section 274Section 276D

…of 35 33. The aforesaid decision was affirmed by the Hon‘ble Supreme Court in Toyota Motor Corporation v. Commissioner of Income- tax: (2008) 306 ITR 52. 34. A Coordinate Bench of this Court in Commissioner of Income Tax v. Sunbeam Auto Ltd.: (2011) 332 ITR 167 had highlighted the necessity to bear in mind the distinction between ―lack of inquiry‖ and ―inadequate enquiry‖. We consider it apposite to refer to the following passage from the said decision: ―17. …Learned counsel for the assessee is right in his submission that one has to keep in mind the distinction between “lack of inquiry” and “inad…

Abroad Vitrified Pvt Ltd, Morbi vs. The Pr. CIT-1, Rajkot

In the result, appeal of assessee is allowed

ITA 144/RJT/2023[2018-19]Status: DisposedITAT Rajkot08 May 2025AY 2018-19

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकरअपीलसं/.Ita Nos.144/Rjt/2023 "नधा"रणवष"/Assessment Year : 2018-19

For Appellant: Shri Mehul Ranpura, ARFor Respondent: Shri Sanjay Punglia, CIT-DR

Section 143(3)Section 263Section 68

…there is difference between ‘Lack of enquiry’ and ‘inadequate enquiry’. It is for the AO to decide the extent of enquiry to be made as it is his satisfaction as what is required under law. Reliance is placed on the decision of CIT v. Sunbeam Auto Ltd. [(2010) 332 ITR 167], wherein Hon’ble Delhi High Court has held that if there was any inquiry, even inadequate, that would not by itself, give occasion to the Commissioner to pass order u/s 263 of the Act, merely because the Commissioner has a different opinion in the matter and that only in cases where there is no enquiry, the power u/s 263 of the Act can be exerci…

M R Patel and Sons, South Tower, Ambli Bopal Road vs. Principal Commissioner of Income Tax-1, Aayakar Bhawan (Vejalpur), Nr Sachin Tower, Anandnagar Prahladnagar Road, Ahmedabad

In the result the appeal filed by the assessee is allowed

ITA 523/AHD/2024[2014-15]Status: DisposedITAT Ahmedabad08 May 2025AY 2014-15

Bench: Smt. Annapurna Gupta (Accountant Member), Shri T. R. Senthil Kumar (Judicial Member)

Section 143Section 143(3)Section 147Section 148

…of limitation as provided under the Act, which is not permissible under the law. Further "Inadequacy" of inquiry by AO also cannot be ground for proceedings under section 263 of the Act as held by the Delhi High Court in the case of CIT vs. Sunbeam Auto Ltd. 332 ITR 167 (Delhi). I.T.A No. 523/Ahd/2024 A.Y. 2014-15 Page No 12 M R Patel And Sons vs. PCIT 10. We are of the considered opinion that the revisionary jurisdiction under Section 263 was wrongly exercised in this case by the LPCIT. For all the above reasons, the entire Revision proceedings is liable to be quashed. 11. In the result the appeal filed by t…

Assotech Moonshine Urban Developers P.Ltd, New Delhi vs. ACIT, Circle-1(1), New Delhi

In the result, the appeal of the assessee is allowed

ITA 2524/DEL/2022[2014-15]Status: DisposedITAT Delhi08 May 2025AY 2014-15

Bench: Shri Challa Nagendra Prasad & Shri Avdhesh Kumar Mishra

Section 142(1)Section 143(3)Section 147Section 14ASection 263

…s of facts arrived at by the Tribunal do not warrant interference of this court. That being the position, the present case would not be one of "lack of inquiry" and, even if the inquiry was termed inadequate, following the decision in Sunbeam Auto Ltd. (2011) 332 ITR 167 (Delhi) (page 180) : "that would not by itself give occasion to the Commissioner to pass orders under section 263 of the Act, merely because he has a different opinion in the matter." No substantial question of law arises for our consideration." 24. In Ashish Rajpal as well, this Court was of the view that the fact that a query was raised during…

Venetian Ldf Projects LLP, Gurgaon vs. ACIT Circle-4(1), Gurgaon

In the result, grounds raised by the assessee are dismissed

ITA 3533/DEL/2019[2014-15]Status: DisposedITAT Delhi01 May 2025AY 2014-15

Bench: Shri S. Rifaur Rahman & Shri Vimal Kumar

Section 143(1)Section 143(3)Section 263Section 40A(2)

…nducted during the course of assessment. - PCIT v. NYA International: [2025] 173 taxmann.com 102 (Guj.) – Revenue’s SLP dismissed in [2025] 173 taxmann.com 103 (SC) - PCIT v. Clix Finance India (P.) Ltd.: [2025] 473 ITR 650 (Delhi) - CIT vs. Sunbeam Auto Ltd: 332 ITR 167 (Del) - CIT v. International Travel House: 344 ITR 554 (Del) - CIT vs. Vikas Polymers: 341 ITR 537 (Del) - Gulmohar Finances Limited: 170 Taxman 483 (Del.) - Fab India Overseas vs. CIT: 244 CTR 380 (Del.) - CIT vs. Vodafone Essar: 212 Taxman 184 (Del.) 42 - CIT vs. DLF Ltd.: 350 ITR 555 (Del) - CIT v. Ratlam Coal Ash Co: 171 ITR 141 (MP) - CIT vs…

Shiv Green Energy Private Limited, Jamnagar vs. Principal Commissioner of Income Tax, Jamnagar

In the result, appeals filed by the assessees(ITA No

ITA 595/RJT/2024[2018-19]Status: DisposedITAT Rajkot30 Apr 2025AY 2018-19

Bench: Dr. Arjun Lal Saini, Am. & Dinesh Mohan Sinha, Jm आयकरअपीलसं./Ita No. 595/Rjt/2024 "नधा"रणवष" / Assessment Year: (2018-19) (Hybrid Hearing) Shiv Green Energy Pvt. Ltd. Vs. The Principal Commissioner Of Income Tax, 107, Divyam Park, Jamnagar 361001 Opp. H.O. Bhatt Bunglow, Nr. Sanjeevani Medical Store, Jamnagar - 361006 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aascs8645J (Appellant) (Respondent)

For Appellant: Shri Mahesh Paun, Ld. ARFor Respondent: ShriSanjay Pungalia, Ld. CIT. (DR)

Section 143(3)Section 263

…ible views and the assessment order passed by the assessing officer could not be held to be prejudicial to the Revenue. We derive support for our conclusions, as above, from the decision of the Hon'ble Delhi High Court in the case of CIT Vs. Sunbeam Auto Ltd. 332 ITR 167 (Del.). For reasons stated above, we are of the view that the jurisdiction u/s.263 of the Act was not properly exercised by the PCIT, as the condition precedent for invoking the same viz., that the order of the assessing officer is erroneous and prejudicial to the interest of the revenue, is not shown to be present in the present case. We therefo…

Ashok Gopaldas Vithlani, Jamkhambhaliya vs. Principal Commissioner of Income Tax, Jamnagar

In the result, appeals filed by the assessees(ITA No

ITA 229/RJT/2024[2017-18]Status: DisposedITAT Rajkot30 Apr 2025AY 2017-18

For Appellant: Shri Mahesh Paun, Ld. ARFor Respondent: ShriSanjay Pungalia, Ld. CIT. (DR)

Section 143(3)Section 263

Shree Samarth Electricals Pvt Ltd, Jamnagar vs. Principal Commissioner of Income Tax, Jamnagar

ITA 610/RJT/2024[2018-19]Status: DisposedITAT Rajkot25 Apr 2025AY 2018-19

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinha

For Appellant: Shri Mahesh Paun, ld.ARFor Respondent: Shri Sanjay Punglia, ld.CIT-DR

Section 133ASection 143(3)Section 263Section 69

…e held to be GojijyaBhikhubhai and Others ITA No.609, 610 and 612/RJT/2024 (AY :2018-19) 23 prejudicial to the Revenue. We derive support for our conclusions, as above, from the decision of the Hon'ble Delhi High Court in the case of CIT Vs. Sunbeam Auto Ltd. 332 ITR 167 (Del.). For reasons stated above, we are of the view that the jurisdiction u/s.263 of the Act was not properly exercised by the PCIT, as the condition precedent for invoking the same viz., that the order of the assessing officer is erroneous and prejudicial to the interest of the revenue, is not shown to be present in the present case. We therefo…

Shree Samarth Switchgear and Transmission Pvt Ltd, Jamnagar vs. Principal Commissioner of Income Tax, Jamnagar

ITA 609/RJT/2024[2018-19]Status: DisposedITAT Rajkot25 Apr 2025AY 2018-19

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinha

For Appellant: Shri Mahesh Paun, ld.ARFor Respondent: Shri Sanjay Punglia, ld.CIT-DR

Section 133ASection 143(3)Section 263Section 69

M/S. Sarju Vitrified Pvt. Ltd., Morbi-363641 vs. The Pr. CIT-1, Rajkot

ITA 83/RJT/2023[2018-19]Status: DisposedITAT Rajkot24 Apr 2025AY 2018-19

Section 142(1)Section 143(3)Section 263Section 68Section 68o

…M/s.Sarju Vitrified P Ltd. ITA No.83/RJT/2023 (AY: 2018-19) 2 1. The order u/s. 263 of the Act is bad in law. 2.The learned Pr. CIT has erred in law as well as on facts in not considering the submissions of the assessee on the strength of which the assessment order was neither erroneous nor prejudicial to the interest of revenue and therefore, the provisions of Section 263 of the Act were not applicable to the case of the assessee. 3.The learned Pr. CIT has erred in law as well as on facts in not appreciating that under the provisions of Section 68 as applicable to the year under appeal, the assessee was not requ…

Mmtc Ltd vs. DCIT Circle 5(1)

In the result the appeal of the assessee is allowed

ITA 2732/DEL/2006[2004-2005]Status: DisposedITAT Delhi23 Apr 2025AY 2004-2005

Bench: Shri M. Balaganesh & Shri Yogesh Kumar U.S.Clix Capital Services Pvt. Ltd, Vs. Pcit, Plot No. 23, 5Th Floor, Aggarwal Delhi-1, Delhi Corporate Tower Govind Lal Sikka Marg, Rajendra Place, West Delhi, New Delhi, Delhi, India, 110008 (Appellant) (Respondent) Pan: Aaacc0642F

For Appellant: Shri Ajay Vohra, Sr. AdvFor Respondent: Shri Sanjay Kumar Bharati, CIT DR

Section 139(1)Section 143(3)Section 144BSection 263Section 37

…it does not automatically tantamount to non-enquiry by the ld AO and assessment being framed with non application of mind by the ld AO. Reliance in this regard is rightly placed by the ld AR on the following decisions:- a. CIT Vs. Sunbeam Auto Ltd reported in 332 ITR 167 (Del) b. CIT Vs. Anil Kumar Sharma reported in 335 ITR 83 (Del) c. CIT Vs. Amalgamations Ltd reported in 238 ITR 963 (Mad) d. Hari Iron Trading Company Vs. CIT reported in 263 ITR 437 (P&H) e. CIT Vs. Eicher Ltd reported in 294 ITR 310 (Del) f. CIT Vs. Gabriel India Ltd reported in 203 ITR 108 (Bom) 8. Respectfully following the aforesaid decisio…

Shri Princepreetjit Singh, Ranjit Nagar vs. Pr.CIT-1, Chandigarh

In the result, appeal of the assessee is allowed

ITA 54/CHANDI/2021[2015-16]Status: DisposedITAT Chandigarh21 Apr 2025AY 2015-16

Bench: SHRI. RAJPAL YADAV (Vice President), SHRI. KRINWANT SAHAY (Accountant Member)

For Appellant: Shri Parikshit Aggarwal, C.AFor Respondent: Shri Chandrajit Singh, CIT, DR(Virtual)

Section 143(3)Section 263Section 54BSection 54F

…xamined by the Ld.AO in the original assessment framed u/s 143(3) revisionary proceedings are not maintainable. For this proposition we, rely upon the following judgements:  Malabar Industrial Co. Ltd. vs CIT (2000) 243 ITR 83 (SC)  CIT vs Sunbeam Auto Ltd. 332 ITR 167 (Del HC)  ITO vs DG Housing Projects Ltd. 343 ITR 329 (Del HC) 14 10. In view of above, it is therefore prayed that the impugned order passed u/s 263 may please be quashed. We shall be highly obliged. 6. Per contra, the Ld. DR relied on the order of the Ld. PCIT. 7. We have heard the rival contention of both the parties and also perused the ma…

Daya Ram, Gurgaon vs. PCIT, Rohtak

In the result, appeal of the assessee is allowed

ITA 2268/DEL/2024[2013-14]Status: DisposedITAT Delhi17 Apr 2025AY 2013-14

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwaldaya Ram, Vs. Pcit, Village Patauda Khera, Rohtak Po Patauda, Distt-Jhajjar, Haryana (Appellant) (Respondent) Pan: Avrpr0237L Assessee By : Shri Jai Bhagwan Saini, Adv Revenue By: Shri Surender Pal, Cit Dr Date Of Hearing 17/04/2025 Date Of Pronouncement 17/04/2025

For Appellant: Shri Jai Bhagwan Saini, AdvFor Respondent: Shri Surender Pal, CIT DR

Section 10(37)Section 142(1)Section 143Section 143(1)(a)Section 143(2)Section 143(3)Section 147Section 263Section 28Section 56(2)(viii)

…d. AO did not make elaborate discussion but was satisfied with the explanation of the a s s e s s e e , th e o rd e r c o u ld n o t b e h e l d t o b e e rro n e o u s . In support the decisions of Hon'ble Delhi High Court in CIT vs. Sunbeam Auto Ltd. (2011) 332 ITR 167 (Del) and decision of Hon'ble Rajasthan High Court in CIT vs. Ganpat Ram Bisnoi 296 ITR 292 (Raj.) were cited. Daya Ram 6.2 The Ld. AR invited our attention to Audit Memo at pages 399-402 of Paper Book in the case of the assessee wherein ITO (Audit) Hisar raised an audit objection observing that interest under section 28 of Land Acquisition Act…

Grade One Events Pvt. Ltd., Ghaziabad vs. DCIT, Circle- 1, Ghaziabad

In the result, the captioned appeals filed by the assessees are allowed

ITA 1831/DEL/2018[2012-13]Status: DisposedITAT Delhi16 Apr 2025AY 2012-13

Bench: Ms. Madhumita Roy & Shri Naveen Chandraa.Y. 2013-14 A.Y. 2014-15 A.Y. 2015-16 A.Y. 2016-17 A.Y. 2017-18 A.Y. 2019-20 A.Y. 2018-19

Section 24Section 263Section 263(1)

…n taken by the AO in the assessment order the same cannot be held to be prejudicial to the interests of Revenue. In support of his contention Ld. AR relied upon the decision of the Hon’ble Delhi High Court in the case of CIT v. Sunbeam Auto Pvt. Ltd. [2011] 332 ITR 167 (Del.), which has been duly considered by us and found to be applicable in the case in hand having regard to the facts and circumstances of the case. Thus, when the claims of the assessee have been duly examined during original assessment proceedings and also the reassessment proceedings under Section 153A of the Act itself, there could have be…

Clix Capital Services Private Limited, Delhi vs. Principal Commissioner of Income Tax, Delhi-1, Delhi

In the result the appeal of the assessee is allowed

ITA 2732/DEL/2024[2018-19]Status: DisposedITAT Delhi15 Apr 2025AY 2018-19

For Appellant: Shri Ajay Vohra, Sr. AdvFor Respondent: Shri Sanjay Kumar Bharati, CIT DR

Section 139(1)Section 143(3)Section 144BSection 263Section 37

Goel Eisha Capitals, Pune vs. PCIT(Central), Pune

ITA 1006/PUN/2024[AY 2019 - 20]Status: DisposedITAT Pune07 Apr 2025

Bench: Shri R. K. Panda & Ms Astha Chandra

For Appellant: Shri Krishna GujarathiFor Respondent: Shri Amol Khairnar, CIT-DR

Section 132Section 142(1)Section 143(2)Section 143(3)Section 263

…ome Tax by invoking revisionary powers under section 263 of the Act cannot impose his own understanding of the extent of inquiry. There were a number of judgments by various High Courts in this regard. 12.2 Delhi High Court in the case of CIT Vs. Sunbeam Auto 332 ITR 167 (Del.), made a distinction between lack of inquiry and inadequate inquiry. The Hon'ble court held that where the AO has made inquiry prior to the completion of assessment, the same cannot be set aside u/s 263 on the ground of inadequate inquiry “12...... There are judgments galore laying down the principle that the Assessing Officer in the assess…