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“lack of enquiry”

Rectification & RevisionSection 263Section 263780 judgments

The decision most relied on for lack of enquiry is Malabar Industrial Co. Ltd. v. CIT (243 ITR 83), cited in 2,943 judgments on BharatTax.

Leading authorities on lack of enquiry

Malabar Industrial Co. Ltd. v. CIT
243 ITR 83 · 2000 · Supreme Court
2,943
citing judgments

For revision under Section 263, the Assessing Officer's order must be both erroneous and prejudicial to the interests of the revenue; if either condition is not met, the revisionary jurisdiction cannot be invoked. An order is not erroneous merely because the Assessing Officer did not record the details of enquiries conducted, provided due enquiries were made.

CIT v. Sunbeam Auto Ltd.
332 ITR 167 · 2011 · High Court
897
citing judgments

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.

ITO v. D.G. Housing Projects Ltd.
343 ITR 329 · 2012 · High Court
438
citing judgments

For exercising revisional jurisdiction under Section 263, the Commissioner must first find that the Assessing Officer's order is erroneous and unsustainable in law, as this is a condition precedent. An order is not erroneous merely because two views are possible, or if the Commissioner disagrees with the Assessing Officer's permissible view, or to simply remit the matter for further enquiries.

CIT v. Vikas Polymers
341 ITR 537 · 2012 · High Court
318
citing judgments

An assessment order is not erroneous and prejudicial under Section 263 merely because the Assessing Officer did not record an enquiry and its satisfactory answer in the assessment order, provided such an enquiry was conducted. For revision under Section 263, the Commissioner must also provide the assessee an opportunity of being heard and examine their explanation.

CIT v. Anil Kumar Sharma
335 ITR 83 · 2011 · High Court
264
citing judgments

The Commissioner cannot invoke Section 263 for an assessment merely because of an inadequate inquiry by the Assessing Officer, provided there was some inquiry or the record demonstrates application of mind, as this constitutes a mere difference of opinion.

Narayan Tatu Rane v. ITO
70 Taxmann.com 227 · 2016 · ITAT
220
citing judgments

Before revising an assessment order under Section 263, the CIT/PCIT must conduct their own inquiries or verifications to establish that the Assessing Officer's order is erroneous and unsustainable in law, rather than merely directing further inquiry or pointing out the AO's lack of inquiry.

DIT v. Jyoti Foundation
357 ITR 388 · 2013 · High Court
210
citing judgments

An assessment order cannot be deemed erroneous and prejudicial to the interest of revenue under Section 263 if the Assessing Officer conducted an inquiry and applied their mind during the original assessment, as Explanation 2 to Section 263 does not permit unending inquiries by the revisional authority.

CIT v. Infosys Technologies Ltd.
341 ITR 293 · 2012 · High Court
205
citing judgments

A Commissioner can revise an assessment order under Section 263 if it is erroneous and prejudicial to the interests of the revenue. This includes cases where the Assessing Officer fails to make further inquiries before accepting the assessee's statements in the return.

Judgments citing lack of enquiry

Asian Institute of Gastroenterology Private Limited, Hyderabad vs. DCIT., Circle-1(1), Hyderabad

In the result, appeals filed by the assessee for

ITA 609/HYD/2025[2020-21]Status: DisposedITAT Hyderabad11 Jul 2025AY 2020-21

Bench: Shri Manjunatha G & Shri Ravish Sood

For Appellant: CA, S. VenugopalFor Respondent: Shri B. Bala Krishna, CIT-DR
Section 143(3)Section 14ASection 263

matter to the Assessing Officer to decide whether the findings recorded are erroneous. In cases where there is inadequate enquiry but not lack of enquiry, again the CIT must give and record a finding that the order/inquiry made is erroneous. This can happen if an enquiry and verification is conducted ... merits. As held above, a distinction must be drawn in the cases where the Assessing Officer does not conduct an enquiry; as lack of enquiry by itself renders the order being erroneous and prejudicial to the interest of the Revenue and cases where the Assessing Officer conducts enquiry but finding

Anunta Technology Management Services Limited, Mumbai vs. Deputy Commissioner of Income Tax, Circle 4(1)(1), Mumbai

In the result, the appeal by the assessee is allowed

ITA 2407/MUM/2025[2020-21]Status: DisposedITAT Mumbai09 Jul 2025AY 2020-21

Bench: Shri Narendra Kumar Billaiyashri Sandeep Singh Karhailanunta Technology Management Services Ltd., Level – 2, Block – 6, Nirlon Knowledge Park, Goregaon East, S.O. Mumbai ............... Appellant Mumbai - 400063 Pan : Aakca6159M V/S Dcit – 4(1)(1), ……………… Respondent Mumbai Assessee By : Shri K.K. Ved Revenue By : Shri Rajesh Kumar Yadav, Cit-Dr

For Appellant: Shri K.K. VedFor Respondent: Shri Rajesh Kumar Yadav, CIT-DR
Section 142(1)Section 143(2)Section 143(3)Section 144BSection 263Section 37(1)

that there was any enquiry on this issue by the AO There are several decisions of the high courts wherein no enquiry or lack of enquiry by the AO on any issue in assessment proceeding has been held fit for revision u/s263 of the Act. On merits also, the assessee

Karam Vir Yadav, Gurgaon vs. Assessing Officer, NFAC

In the result, the appeal filed by the assessee is allowed

ITA 2605/DEL/2024[2020-21]Status: DisposedITAT Delhi09 Jul 2025AY 2020-21

Bench: Shri S. Rifaur Rahman & Shri Anubhav Sharmakaramvir Yadav, Vs. Assessing Officer, 1135, Sector 46, Nfac, Delhi. Gurgaon – 122 001 (Haryana). (Pan : Abipy5863E) (Appellant) (Respondent) Assessee By : Shri Ranjan Chopra, Ca Revenue By : Shri Kailash Dan Ratnoo, Cit Dr Date Of Hearing : 30.04.2025 Date Of Order : 09.07.2025 O R D E R Per S.Rifaur Rahman: 1. This Appeal Is Filed By The Assessee Against The Order Of Ld. Commissioner Of Income-Tax (Appeals)/National Faceless Appeal Centre (Nfac), Delhi [Hereinafter Referred To As ‘Ld. Cit (A)] Dated 29.03.2024 For Assessment Year 2020-21 Raising Following Grounds Of Appeal :- “1. That Having Regard To The Facts & Circumstances Of The Case & In Law, The Order Under Section 263 Of The Income-Tax Assessee Company, 1961. 2. That Having Regard To The Facts & Circumstances Of The Case & In Law, The Learned Pr. Cit Erred In Passing Order U/S 263 Of The Act, So Much So That, The Assessment Order Passed By The Assessing Officer Do Not Satisfy The Statutory Twin Conditions Prescribed Under Section 263 Of The Act, Viz., (I) That The Assessment

For Appellant: Shri Ranjan Chopra, CAFor Respondent: Shri Kailash Dan Ratnoo, CIT DR
Section 143(3)Section 263Section 28

otherwise too inapplicable on the factual matrix of the facts of the instant case since it is not a case of "lack of enquiry" or "lack of investigation" and therefore the invocation u/s 263 of the Act is not in accordance with law. 6. That furthermore the learned Principal Commissioner

Satyanaga Veera Anjaneya Babu Gutta, Hyderabad vs. ITO., Ward - 13(5), Hyderabad

In the result, the appeal of the assessee is allowed for statistical purposes

ITA 442/HYD/2025[2017-18]Status: DisposedITAT Hyderabad08 Jul 2025AY 2017-18

Bench: Shri Ravish Sood & Shri Madhusudan Sawdia

For Appellant: Shri K.A. Sai Prasad, C.AFor Respondent: : Shri Abhinav Pitta, SR-DR
Section 133(6)Section 143(2)Section 143(3)Section 69A

that the assessee was not granted ITA No.664/Hyd/2025 6 sufficient opportunity to substantiate this transaction appears justified in view of the lack of enquiry or adverse material. In these circumstances, in the interest of natural justice, we are inclined to restore this issue to the file

Rama Rani, Chandigarh vs. DCIT, Circle 1(1), Chandigarh

The appeal stand allowed in terms of our above order

ITA 933/CHANDI/2024[2015-16]Status: DisposedITAT Chandigarh04 Jul 2025AY 2015-16

Bench: Hon’Ble Shri Laliet Kumar, Jm & Hon’Ble Shri Manoj Kumar Aggarwal, Am आयकरअपीलसं./ Ita No. 933/Chandi/2024 (िनधा"रणवष" / Assessment Year: 2015-16 Ms. Rama Rani Dcit बनाम/ Vs. H. No 1058, Popular Enclave Circle 1(1), Sector 48-B, Chandigarh Chandigarh. "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aerpr-2072-Q (अपीलाथ"/Appellant) : (""थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Sh. Ravinder Krishan (Advocate)– Ld. Ar ""थ"कीओरसे/Respondent By : Sh. Rajat Kumar Kureel (Cit) – Ld. Dr सुनवाईकीतारीख/Date Of Hearing : 30-06-2025 घोषणाकीतारीख /Date Of Pronouncement : 04-07-2025 आदेश / O R D E R Manoj Kumar Aggarwal () 1. By Way Of This Appeal, The Assessee Assails Invocation Of Revisionary Jurisdiction U/S 263 By Ld. Pr. Commissioner Of Income Tax, Chandigarh-1 (Pr.Cit) For Assessment Year (Ay) 2015-16 Vide Impugned Order Dated 14-03-2024 Proposing Revision Of Assessment As Framed By Ld. Ao U/S.147 Of The Act On 29-03-2022. The Registry Has Noted Delay Of 98 Days In The Appeal, The Condonation Of Which Has Been Sought By Ld. Ar On The Strength Of Condonation Petition Which Is Accompanied By An Affidavit Of The Assessee. It Has Been Stated That The Assessee Was Not In India When

For Appellant: Sh. Ravinder Krishan (Advocate)– Ld. ARFor Respondent: Sh. Rajat Kumar Kureel (CIT) – Ld. DR
Section 142(1)Section 143(3)Section 147Section 263Section 54F

mind to the impugned issue not only at the time of original assessment proceedings but also during reassessment proceeding and there was no lack of enquiry as alleged. In this background, the assessee assailed revision of the order. However, Ld. Pr. CIT ordered for revision of the order and directed

Soham Papers Private Limited, Morbi vs. Pr. CIT, Rajkot-1, Rajkot

ITA 371/RJT/2024[2019-20]Status: DisposedITAT Rajkot30 Jun 2025AY 2019-20

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

Section 115BSection 143(3)Section 263Section 69A

assessment order passed by him could not be held to be erroneous and prejudicial to the interests of revenue. 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 ... failed to make proper enquiry which he ought to have made before completing the assessment. We note that there is a distinction between "lack of enquiry" and "inadequate enquiry. If there is an enquiry, even inadequate, that would not by itself give occasion to the PCIT to pass order under

M/S. Dhruv Craft Mill Pvt. Ltd., Morbi vs. The Principal Commissioner of Income Tax-1, Rajkot

ITA 335/RJT/2024[2019-20]Status: DisposedITAT Rajkot30 Jun 2025AY 2019-20

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

Section 11SSection 143(3)Section 263Section 69A

assessment order passed by him could not be held to be erroneous and prejudicial to the interests of revenue. 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 ... failed to make proper enquiry which he ought to have made before completing the assessment. We note that there is a distinction between "lack of enquiry" and "inadequate enquiry. If there is an enquiry, even inadequate, that would not by itself give occasion to the PCIT to pass order under

Dhruv Print Pack Industries, Morbi vs. Pr. CIT, Rajkot-1, Rajkot

ITA 331/RJT/2024[2019-20]Status: DisposedITAT Rajkot30 Jun 2025AY 2019-20

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

Section 11SSection 143(3)Section 263Section 69A

assessment order passed by him could not be held to be erroneous and prejudicial to the interests of revenue. 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 ... failed to make proper enquiry which he ought to have made before completing the assessment. We note that there is a distinction between "lack of enquiry" and "inadequate enquiry. If there is an enquiry, even inadequate, that would not by itself give occasion to the PCIT to pass order under

Hetalkumar Pravinchandra Rajyaguru, Rajkot vs. Pr. CIT, Rajkot-1, Rajkot

ITA 329/RJT/2024[2018-19]Status: DisposedITAT Rajkot30 Jun 2025AY 2018-19

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

Section 11SSection 143(3)Section 263Section 69A

assessment order passed by him could not be held to be erroneous and prejudicial to the interests of revenue. 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 ... failed to make proper enquiry which he ought to have made before completing the assessment. We note that there is a distinction between "lack of enquiry" and "inadequate enquiry. If there is an enquiry, even inadequate, that would not by itself give occasion to the PCIT to pass order under

Shamji Nathu Vaishya, Veraval vs. Pr. CIT, Rajkot-1, Rajkot

ITA 327/RJT/2024[2018-19]Status: DisposedITAT Rajkot30 Jun 2025AY 2018-19

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

Section 115BSection 143(3)Section 263Section 69A

assessment order passed by him could not be held to be erroneous and prejudicial to the interests of revenue. 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 ... failed to make proper enquiry which he ought to have made before completing the assessment. We note that there is a distinction between "lack of enquiry" and "inadequate enquiry. If there is an enquiry, even inadequate, that would not by itself give occasion to the PCIT to pass order under

Kishor Veljibhai Fofandi, Veraval vs. Pr. CIT, Rajkot-1, Rajkot

ITA 326/RJT/2024[2019-20]Status: DisposedITAT Rajkot30 Jun 2025AY 2019-20

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

Section 115BSection 143(3)Section 263Section 69A

assessment order passed by him could not be held to be erroneous and prejudicial to the interests of revenue. 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 ... failed to make proper enquiry which he ought to have made before completing the assessment. We note that there is a distinction between "lack of enquiry" and "inadequate enquiry. If there is an enquiry, even inadequate, that would not by itself give occasion to the PCIT to pass order under

Deepmala Marine Exports, Veraval vs. Pr. CIT, Rajkot-1, Rajkot

ITA 324/RJT/2024[2019-20]Status: DisposedITAT Rajkot30 Jun 2025AY 2019-20

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

Section 115BSection 143(3)Section 263Section 69A

assessment order passed by him could not be held to be erroneous and prejudicial to the interests of revenue. 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 ... failed to make proper enquiry which he ought to have made before completing the assessment. We note that there is a distinction between "lack of enquiry" and "inadequate enquiry. If there is an enquiry, even inadequate, that would not by itself give occasion to the PCIT to pass order under

Chunilal Govind Vanik, Veraval vs. Pr. CIT, Rajkot-1, Rajkot

ITA 323/RJT/2024[2019-20]Status: DisposedITAT Rajkot30 Jun 2025AY 2019-20

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

Section 115BSection 143(3)Section 263Section 69A

assessment order passed by him could not be held to be erroneous and prejudicial to the interests of revenue. 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 ... failed to make proper enquiry which he ought to have made before completing the assessment. We note that there is a distinction between "lack of enquiry" and "inadequate enquiry. If there is an enquiry, even inadequate, that would not by itself give occasion to the PCIT to pass order under

Sun Exports, Veraval vs. Pr. CIT, Rajkot-1, Rajkot

ITA 322/RJT/2024[2019-20]Status: DisposedITAT Rajkot30 Jun 2025AY 2019-20

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

Section 11SSection 143(3)Section 263Section 69A

assessment order passed by him could not be held to be erroneous and prejudicial to the interests of revenue. 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 ... failed to make proper enquiry which he ought to have made before completing the assessment. We note that there is a distinction between "lack of enquiry" and "inadequate enquiry. If there is an enquiry, even inadequate, that would not by itself give occasion to the PCIT to pass order under

Bharatkumar Kalyanjibhai Bhindi, Junagadh vs. PCIT, Rajkot-1, Rajkot

ITA 312/RJT/2024[2019-20]Status: DisposedITAT Rajkot30 Jun 2025AY 2019-20

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhasr. No. 1. 2. 3. 4. 5. 6. 7. 8. 9. 10. 324/Rjt/2024 322/Rjt/2024 323/Rjt/2024 312/Rjt/2024 326/Rjt/2024 327/Rjt/2024 329/Rjt/2024 331/Rjt/2024 335/Rjt/2024 371/Rjt/2024

Section 115BSection 143(3)Section 263Section 69A

assessment order passed by him could not be held to be erroneous and prejudicial to the interests of revenue. 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 ... failed to make proper enquiry which he ought to have made before completing the assessment. We note that there is a distinction between "lack of enquiry" and "inadequate enquiry. If there is an enquiry, even inadequate, that would not by itself give occasion to the PCIT to pass order under

Muhammad Zameer Qureshi, Bareilly vs. Pr. CIT, Bareilly

The appeal of the assessee stands allowed

ITA 344/LKW/2024[2014-15]Status: DisposedITAT Lucknow30 Jun 2025AY 2014-15

Bench: Shri. Sudhanshu Srivastava & Shri Nikhil Choudharyassessment Year: 2014-15 Shri Muhammad Zameer Qureshi V. The Pcit 180, Azam Nagar Bareilly Bareilly Tan/Pan:Aacpz6783H (Appellant) (Respondent) Appellant By: Shri P. K. Kapoor, C.A. Respondent By: Shri Neeraj Kumar, Cit(Dr) O R D E R

For Appellant: Shri P. K. Kapoor, C.AFor Respondent: Shri Neeraj Kumar, CIT(DR)
Section 139(4)Section 144BSection 147Section 148Section 263Section 69

order he did not make an elaborate discussion in that regard." 5.2 Further, in cases where there is alleged inadequate enquiry but not lack of enquiry, again the Ld. PCIT must give and record a finding that the order/inquiry made is erroneous. This can happen only if an enquiry

Surender Kumar, Gurgaon vs. ITO, Ward 4 (1), Gurgaon

In the result, appeal of the assessee is allowed

ITA 351/DEL/2025[2017-18]Status: DisposedITAT Delhi30 Jun 2025AY 2017-18

Bench: Shri Satbeer Singh Godara & Shri S. Rifaur Rahman

Section 142(1)Section 143Section 143(1)(a)Section 143(2)Section 143(3)Section 147Section 263Section 28Section 56(2)(viii)Section 57

which he ought to have carried out in respect of the enhanced compensation received by the assessee. It is not a case of ‘lack of enquiry’. Merely because in his order the Ld. AO did not make elaborate discussion but was satisfied with the explanation of the assessee, the order ... evidence available on records, it cannot be alleged as done by the Ld. PCIT that it is a case of 'no enquiry’ or ‘lack of enquiry’. No doubt that the Ld. AO did not discuss elaborately in the assessment order but that alone cannot make the order erroneous as held

Imperial Housing Ventures Private Limited, Delhi vs. Pr, CIT Central Delhi-2, Delhi

In the result, the appeal filed by the assessee is allowed

ITA 2345/DEL/2024[2018-19]Status: DisposedITAT Delhi30 Jun 2025AY 2018-19

Bench: Shri S.Rifaur Rahman & Shri Anubhav Sharmaimperial Housing Ventures Pvt. Ltd., Vs. Pr.Cit (Central), Room No.205, Welcome Plaza, Delhi-2. Sector 54, Golf Course Road, Shakarpur, East Delhi, Delhi – 110 092. (Pan : Aacci2023E) (Appellant) (Respondent) Assessee By : Shri Salil Aggarwal, Sr. Advocate Shri Shailesh Gupta, Advocate Revenue By : Shri Kailash Dan Ratnoo, Cit Dr Date Of Hearing : 30.04.2025 Date Of Order : 30.06.2025 O R D E R Per S.Rifaur Rahman:

For Appellant: Shri Salil Aggarwal, Sr. AdvocateFor Respondent: Shri Kailash Dan Ratnoo, CIT DR
Section 143(3)Section 14ASection 194Section 199

IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH ‘C’: NEW DELHI BEFORE SHRI S.RIFAUR RAHMAN, ACCOUNTANT MEMBER and SHRI ANUBHAV

Ct. Ramanathan (HUF), Pudukkottai vs. PCIT 1, Madurai

Appeal of the assessee is allowed

ITA 761/CHNY/2025[2020-21]Status: DisposedITAT Chennai25 Jun 2025AY 2020-21

Bench: Hon’Ble Shri Manu Kumar Giri & Hon’Ble Shri S.R. Raghunathaआयकर अपील सं./Ita No.761/Chny/2025 Assessment Years: 2020-21 C.T.Ramanathan(Huf), Income Tax Officer, No.7/45, Ct.Rm.S.House, M.St.S. Street Ward-1, Kulipirai, Pudukottai Dist, Pudukottai. Tamil Nadu-622 402. [Pan: Aaahc0701L] (प्रत्यर्थी/Respondent) (अपीलार्थी/Appellant) अपीलार्थी की ओर से/ Assessee By : Mr.V.Subbarayan, Dcit(Retd.) प्रत्यर्थी की ओर से /Revenue By : Mr.M.K.Biju, Cir Dr By Virtual. सुनवाई की तारीख/Date Of Hearing : 03.06.2025 घोषणा की तारीख /Date Of Pronouncement : 25.06.2025 आदेश / O R D E R

For Appellant: Mr.V.Subbarayan, DCIT(Retd.)For Respondent: Mr.M.K.Biju, CIR DR by virtual
Section 143(3)Section 263Section 3

cannot be a ground for proceedings under Section 263 of the Act. It is a settled principle that there is a distinction between "lack of enquiry' and 'inadequate enquiry. It is only in cases of lack of inquiry that such a Page - 15 - of 26 ITA No.761 /Chny/2025 course ... Officer had not made any enquiry then it could be said that the order passed was erroneous. This is not a case of lack of enquiry though it may be a case of inadequate enquiry. Inadequacy of enquiry as elucidated above does not give jurisdiction to the CIT to invoke

Krishnasamy Bhuvaneswari, Coimbatore vs. ITO, Non Corprate Ward 4(2), Coimbatore

In the result, appeal filed by the assessee is treated as allowed for statistical purposes

ITA 1528/CHNY/2023[2013-14]Status: DisposedITAT Chennai25 Jun 2025AY 2013-14

Bench: Shri Manu Kumar Giri & Shri S. R. Raghunathaआयकर अपील सं./Ita No.:1528/Chny/2023 िनधा"रण वष" / Assessment Year:2013-14 Krishnasamy Bhuvaneswari, Ito, 43/63, Rajamanai Thottam, Vs. Non Corporate Ward 4(2), Kupanur, Mathampatty, Coimbatore. Coimbatore – 641 010. [Pan:Ahypb-5938-M] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से/Appellant By : Shri. N. Arjun Raj, Advocate ""थ" की ओर से/Respondent By : Shri. M. K. Biju, C.I.T. - D.R. सुनवाई की तारीख/Date Of Hearing : 05.06.2025 घोषणा की तारीख/Date Of Pronouncement : 25.06.2025

For Appellant: Shri. N. Arjun Raj, AdvocateFor Respondent: Shri. M. K. Biju, C.I.T. - D.R
Section 263Section 263(2)

revisit the issue should be reckoned as bad in law. 7. The PCIT failed to appreciate that the distinction between lack of enquiry and inadequate enquiry was also overlooked before passing the revision order and ought to have appreciated that there could not be any presumption of lack of enquiry