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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

Kartar Singh, Fatehabad vs. Pr. Commissioner of Income Tax, Rohtak

In the result, all the above appeals filed by the respective assessee’s are dismissed

ITA 335/CHANDI/2023[2018-19]Status: DisposedITAT Chandigarh11 Feb 2026AY 2018-19

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

For Appellant: Shri Parikshit Aggarwal, C.A (Virtual)For Respondent: Shri Manav Bansal, CIT, DR

incorrect allowance of exemption. 29. The learned DR submits that this is not a case of inadequate enquiry but a case of complete lack of enquiry. The assessment order is silent on: the head under which interest income was assessed,  the applicability of sections 145B and 56(2)(viii ... incorrect allowance of exemption. 62. The learned DR submits that this is not a case of inadequate enquiry but a case of complete lack of enquiry. The assessment order is silent on: a) the head under which interest income was assessed, b) the applicability of sections 145B

Sh. Ram Lal, Fatehabad vs. Pr.CIT, Rohtak

In the result, all the above appeals filed by the respective assessee’s are dismissed

ITA 332/CHANDI/2023[2018-19]Status: DisposedITAT Chandigarh11 Feb 2026AY 2018-19

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

For Appellant: Shri Parikshit Aggarwal, C.A (Virtual)For Respondent: Shri Manav Bansal, CIT, DR

incorrect allowance of exemption. 29. The learned DR submits that this is not a case of inadequate enquiry but a case of complete lack of enquiry. The assessment order is silent on: the head under which interest income was assessed,  the applicability of sections 145B and 56(2)(viii ... incorrect allowance of exemption. 62. The learned DR submits that this is not a case of inadequate enquiry but a case of complete lack of enquiry. The assessment order is silent on: a) the head under which interest income was assessed, b) the applicability of sections 145B

Bimla Devi, Jagadhri vs. Pr.CIT, Rohtak

In the result, all the above appeals filed by the respective assessee’s are dismissed

ITA 328/CHANDI/2023[2018-19]Status: DisposedITAT Chandigarh11 Feb 2026AY 2018-19

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

For Appellant: Shri Parikshit Aggarwal, C.A (Virtual)For Respondent: Shri Manav Bansal, CIT, DR

incorrect allowance of exemption. 29. The learned DR submits that this is not a case of inadequate enquiry but a case of complete lack of enquiry. The assessment order is silent on: the head under which interest income was assessed,  the applicability of sections 145B and 56(2)(viii ... incorrect allowance of exemption. 62. The learned DR submits that this is not a case of inadequate enquiry but a case of complete lack of enquiry. The assessment order is silent on: a) the head under which interest income was assessed, b) the applicability of sections 145B

Paramjit Singh, Sirsa vs. Pr.CIT, Rohtak

In the result, all the above appeals filed by the respective assessee’s are dismissed

ITA 327/CHANDI/2023[2018-19]Status: DisposedITAT Chandigarh11 Feb 2026AY 2018-19

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

For Appellant: Shri Parikshit Aggarwal, C.A (Virtual)For Respondent: Shri Manav Bansal, CIT, DR

incorrect allowance of exemption. 29. The learned DR submits that this is not a case of inadequate enquiry but a case of complete lack of enquiry. The assessment order is silent on: the head under which interest income was assessed,  the applicability of sections 145B and 56(2)(viii ... incorrect allowance of exemption. 62. The learned DR submits that this is not a case of inadequate enquiry but a case of complete lack of enquiry. The assessment order is silent on: a) the head under which interest income was assessed, b) the applicability of sections 145B

Inder Kaur, Sirsa vs. Pr.CIT, Rohtak

In the result, all the above appeals filed by the respective assessee’s are dismissed

ITA 326/CHANDI/2023[2018-19]Status: DisposedITAT Chandigarh11 Feb 2026AY 2018-19

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

For Appellant: Shri Parikshit Aggarwal, C.A (Virtual)For Respondent: Shri Manav Bansal, CIT, DR

incorrect allowance of exemption. 29. The learned DR submits that this is not a case of inadequate enquiry but a case of complete lack of enquiry. The assessment order is silent on: the head under which interest income was assessed,  the applicability of sections 145B and 56(2)(viii ... incorrect allowance of exemption. 62. The learned DR submits that this is not a case of inadequate enquiry but a case of complete lack of enquiry. The assessment order is silent on: a) the head under which interest income was assessed, b) the applicability of sections 145B

Sh. Amarjeet Singh, Sirsa vs. Pr.CIT, Rohtak

In the result, all the above appeals filed by the respective assessee’s are dismissed

ITA 325/CHANDI/2023[2018-19]Status: DisposedITAT Chandigarh11 Feb 2026AY 2018-19

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

For Appellant: Shri Parikshit Aggarwal, C.A (Virtual)For Respondent: Shri Manav Bansal, CIT, DR

incorrect allowance of exemption. 29. The learned DR submits that this is not a case of inadequate enquiry but a case of complete lack of enquiry. The assessment order is silent on: the head under which interest income was assessed,  the applicability of sections 145B and 56(2)(viii ... incorrect allowance of exemption. 62. The learned DR submits that this is not a case of inadequate enquiry but a case of complete lack of enquiry. The assessment order is silent on: a) the head under which interest income was assessed, b) the applicability of sections 145B

Sh. Gurdeep Singh Mahal, Sirsa vs. Pr.CIT, Rohtak

In the result, all the above appeals filed by the respective assessee’s are dismissed

ITA 233/CHANDI/2023[2018-19]Status: DisposedITAT Chandigarh11 Feb 2026AY 2018-19

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

For Appellant: Shri Parikshit Aggarwal, C.A (Virtual)For Respondent: Shri Manav Bansal, CIT, DR

incorrect allowance of exemption. 29. The learned DR submits that this is not a case of inadequate enquiry but a case of complete lack of enquiry. The assessment order is silent on: the head under which interest income was assessed,  the applicability of sections 145B and 56(2)(viii ... incorrect allowance of exemption. 62. The learned DR submits that this is not a case of inadequate enquiry but a case of complete lack of enquiry. The assessment order is silent on: a) the head under which interest income was assessed, b) the applicability of sections 145B

Sh. Devender Kumar, Yamuna Nagar vs. ITO, Ward -1, Yamuna Nagar

In the result, all the above appeals filed by the respective assessee’s are dismissed

ITA 192/CHANDI/2023[2018-19]Status: DisposedITAT Chandigarh11 Feb 2026AY 2018-19

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

For Appellant: Shri Parikshit Aggarwal, C.A (Virtual)For Respondent: Shri Manav Bansal, CIT, DR

incorrect allowance of exemption. 29. The learned DR submits that this is not a case of inadequate enquiry but a case of complete lack of enquiry. The assessment order is silent on: the head under which interest income was assessed,  the applicability of sections 145B and 56(2)(viii ... incorrect allowance of exemption. 62. The learned DR submits that this is not a case of inadequate enquiry but a case of complete lack of enquiry. The assessment order is silent on: a) the head under which interest income was assessed, b) the applicability of sections 145B

Sh. Baljinder Singh, Chandigarh vs. Pr.CIT, Chandigarh -1, Chandigarh

In the result, all the above appeals filed by the respective assessee’s are dismissed

ITA 167/CHANDI/2023[2018-19]Status: DisposedITAT Chandigarh11 Feb 2026AY 2018-19

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

For Appellant: Shri Parikshit Aggarwal, C.A (Virtual)For Respondent: Shri Manav Bansal, CIT, DR

incorrect allowance of exemption. 29. The learned DR submits that this is not a case of inadequate enquiry but a case of complete lack of enquiry. The assessment order is silent on: the head under which interest income was assessed,  the applicability of sections 145B and 56(2)(viii ... incorrect allowance of exemption. 62. The learned DR submits that this is not a case of inadequate enquiry but a case of complete lack of enquiry. The assessment order is silent on: a) the head under which interest income was assessed, b) the applicability of sections 145B

M/S. Hyundai Motor India Ltd., Kanchipuram vs. PCIT-4, Chennai

In the result, the appeal of the assessee is allowed

ITA 434/CHNY/2025[2012-13]Status: DisposedITAT Chennai11 Feb 2026AY 2012-13

Bench: Shri Manu Kumar Giri & Shri S. R. Raghunatha

For Appellant: Shri. Sriram Seshadri, C.AFor Respondent: Ms. E. Pavuna Sundari, C.I.T
Section 143(3)Section 254Section 263Section 43(1)

same cannot be a ground for proceedings assessee u/s.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 course of action u/s.263 of the Act would ... order is passed without making inquiries or verification which should have been made. However, this Explanation does not obliterate the distinction between “lack of enquiry” and “inadequate enquiry”, a distinction consistently recognised by the Courts. It is only in cases of complete absence of enquiry that revisionary jurisdiction

Rohan Landscape Private Limited, Mumbai vs. The Principle Commissioner of Income Tax, Mumbai

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

ITA 3635/MUM/2025[2020-21]Status: DisposedITAT Mumbai10 Feb 2026AY 2020-21

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI ARUN KHODPIA (Accountant Member)

Section 139(1)Section 142(1)Section 143(2)Section 263Section 3

raise any specific question on allowability of expenditure in a year of no income and that, therefore, the assessment order suffers from lack of enquiry. We are unable to accept this contention. The record clearly shows that the case was selected for complete scrutiny, that notices under section ... grievance can be characterised as one of alleged inadequacy of enquiry. It is settled law that inadequacy of enquiry, as opposed to complete lack of enquiry, does not empower the Commissioner to invoke section 263, particularly when the Assessing Officer has taken a plausible view after examining the material

Satender Kumar, Sarita Vihar vs. Income Tax Officer, Civic Centre

In the result, appeal of the assessee is allowed

ITA 229/DEL/2026[2020-21]Status: DisposedITAT Delhi10 Feb 2026AY 2020-21

Bench: Sh. Satbeer Singh Godaraita No. 229/Del/2026 : Asstt. Year: 2020-21 Satender Kumar, Vs Income Tax Officer, 56, Ali Village, Sarita Vihar, Ward-28(1), New Delhi-110076 New Delhi-110001 (Appellant) (Respondent) Pan No. Afxpk4995C Assessee By: None Revenue By : Sh. Manoj Kumar, Sr. Dr Date Of Hearing: 10.02.2026 Date Of Pronouncement: 10.02.2026 Order This Assessee’S Appeal For Assessment Year 2020-21 Arises Against The Cit(A)/Nfac, Delhi’S Din & Order No. Itba/Nfac/S/250/2025-26/1082434098(1) Dated 10.11.2025, In Proceedings U/S 147 R.W.S. 144 Of The Income Tax Act, 1961 (In Short “The Act”).

For Appellant: NoneFor Respondent: Sh. Manoj Kumar, 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)

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

Braham Dutt Vashist, Gurgaon vs. ITO-Ward -1(3), Gurgaon

In the result, appeal of the assessee is allowed

ITA 170/DEL/2026[2014-15]Status: DisposedITAT Delhi10 Feb 2026AY 2014-15

Bench: Sh. Satbeer Singh Godaraita No. 170/Del/2026 : Asstt. Year: 2014-15 Braham Dutt Vashist, Vs Income Tax Officer, C/O Ca M. R. Sahu, Ward-1(3), H. No. 651, 1St Floor, Sector-10A, Gurgaon-122001 Near G. D. Goenka Public School, Gurgaon-122001 (Appellant) (Respondent) Pan No. Affpv0127D Assessee By: Sh. M. R. Sahu, Ca Revenue By : Sh. Manoj Kumar, Sr. Dr Date Of Hearing: 10.02.2026 Date Of Pronouncement: 10.02.2026 Order This Assessee’S Appeal For Assessment Year 2014-15 Arises Against The Cit(A)/Nfac, Delhi’S Din & Order No. Itba/Nfac/S/250/2025-26/1083989454(1) Dated 23.12.2025, In Proceedings U/S 147 Of The Income Tax Act, 1961 (In Short “The Act”).

For Appellant: Sh. M. R. Sahu, CAFor Respondent: Sh. Manoj Kumar, 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)

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

Ramavtar, Rewari vs. ITO, Rewari

In the result, appeal of the assessee is allowed

ITA 140/DEL/2026[2020-21]Status: DisposedITAT Delhi10 Feb 2026AY 2020-21

Bench: Sh. Satbeer Singh Godaraita No. 140/Del/2026 : Asstt. Year: 2020-21 Ramavtar, Vs Income Tax Officer, C/O Anu Jain & Company, Ward-1(3), 272-R, First Floor, Near Palika Near Hindu High School, Complex, Model Town, Rewari, Model Town, Rewari, Haryana-123401 Haryana-123401 (Appellant) (Respondent) Pan No. Apdpa0001R Assessee By: None Revenue By : Sh. Manoj Kumar, Sr. Dr Date Of Hearing: 10.02.2026 Date Of Pronouncement: 10.02.2026 Order This Assessee’S Appeal For Assessment Year 2020-21 Arises Against The Cit(A)/Nfac, Delhi’S Din & Order No. Itba/Nfac/S/250/2025-26/1083470019(1) Dated 09.12.2025, In Proceedings U/S 147 R.W.S. 144 Of The Income Tax Act, 1961 (In Short “The Act”).

For Appellant: NoneFor Respondent: Sh. Manoj Kumar, 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)

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

Rajesh Sahu, Gurgaon vs. Assessing Officer, Nfau

In the result, appeal of the assessee is allowed

ITA 78/DEL/2026[2018-19]Status: DisposedITAT Delhi09 Feb 2026AY 2018-19

Bench: Shri Satbeer Singh Godaraassessment Year: 2018-19 Sh. Rajesh Sahu, Vs. Assessing Officer, H. No. 2A, Sahu Lane, New Delhi Phase-2, Ashok Vihar, Gurgaon Pan: Avaps9917M (Appellant) (Respondent) Assessee By None Department By Sh. Manoj Kumar, Sr. 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

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

Daulat Ram, Rewari vs. ITO, Rewari (Jao), Rewari

In the result, appeal of the assessee is allowed

ITA 112/DEL/2026[2017-18]Status: DisposedITAT Delhi09 Feb 2026AY 2017-18

Bench: Shri Satbeer Singh Godaraassessment Year: 2017-18 Sh. Daulat Ram, Vs. Income Tax Officer, C/O- Anu Jain & Co., First Rewari (Jao) Floor, Near Palika Complex, Model Town, Rewari Pan: Avppr6711D (Appellant) (Respondent) Assessee By None Department By Sh. Monoj Kumar, Sr. Dr

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

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

Sumanth Badiga, Hyderabad vs. DCIT., Circle - 5(1), Hyderabad

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

ITA 628/HYD/2025[2020-21]Status: DisposedITAT Hyderabad06 Feb 2026AY 2020-21

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdiaआ.अपी.सं /Ita.No.628/Hyd/2025 Assessment Year 2020-2021 Sumanth Badiga, The Dcit, Circle-5(1), Hyderabad – 500 004. Vs. Hyderabad. Telangana. Telangana. Pan Ahqpb8508F (Appellant) (Respondent) निर्धारिती द्वधिध/Assessee By : Ca C S Subrahmanyam & Sri V. Siva Kumar, Advocate िधजस् व द्वधिध/Revenue By : Sri Lv Bhaskara Reddy, Cit-Dr सुिवधई की तधिीख/Date Of Hearing: 02.02.2026 घोषणध की तधिीख/Pronouncement: 06.02.2026 आदेश/Order Per Vijay Pal Rao:

For Appellant: CA C S Subrahmanyam and Sri V. Siva Kumar, AdvocateFor Respondent: Sri LV Bhaskara Reddy, CIT-DR
Section 143(3)Section 263Section 54Section 54F

proper enquiry and without application of mind is erroneous in so far as prejudicial to the interests of the Revenue. A complete lack of enquiry on an issue renders the order of the Assessing Officer erroneous in so far as prejudicial to the interests of the Revenue. Therefore, the decisions ... issue as different Benches of this Tribunal has taken different views on this issue, however, the since the assessment order is erroneous for lack of enquiry, therefore, we do not go into the aspect of interpretation of proviso to sec.54F(1) of the Act. Once the order of the Assessing

Ravindra Dhaka, Gurgaon vs. PCIT, Faridabad

In the result, the appeal of the assessee is dismissed

ITA 2332/DEL/2025[2020-21]Status: DisposedITAT Delhi06 Feb 2026AY 2020-21

Bench: Shri Mahavir Singh & Shri Manish Agarwal[Assessment Year : 2020-21] Ravindra Dhaka Vs Pr.Cit, H.No.-420F, Sector-38, Faridabad Gurgaon-122001 Pan-Afqpd9356P Appellant Respondent Appellant By Shri Vijay Kumar Singla, Ca & Shri Kinshuk Gautam, Ca Respondent By Shri Jitender Singh, Cit Dr Date Of Hearing 04.12.2025 Date Of Pronouncement 06.02.2026

Section 132Section 143(3)Section 153CSection 263

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) The Ld. PCIT has erred

Ambuja Cements Limited, Mumbai vs. PCIT, Mumbai-3, Mumbai

ITA 3474/MUM/2025[2019-20]Status: DisposedITAT Mumbai05 Feb 2026AY 2019-20

Bench: Shri Sandeep Gosain & Shri Prabhash Shankar

For Appellant: Shri Sourabh Soparkar, AR (virtually appear)For Respondent: Shri Rajesh Kumar Yadav, (CIT-DR)
Section 143(3)Section 14ASection 263

taxmann.com 217 (Bom)held that mere issuance of queries without carrying them to their logical conclusion amounts to lack of enquiry, justifying revision under section 263 of the Act. 8. Before proceeding further, it would be appropriate to examine the provisions of section 263 and more specifically the deeming provisions

Golden Sandhar Mills Limited, Punjab vs. ITO, Ward-10(3), Delhi

ITA 5562/DEL/2025[2020-21]Status: DisposedITAT Delhi05 Feb 2026AY 2020-21

Bench: Shri Satbeer Singh Godara & Shri Naveen Chandragolden Sandhar Mills Ltd, Vs. Ito, Sugar Mill Complex Sugar Ward-10(3), Mill, Gt Road Phagwara, Delhi Punjab (Appellant) (Respondent) Pan: Aaacw3332J Assessee By : Shri Parikshit Agarwal, Ca Revenue By: Ms. Monika Singh, Cit Dr Date Of Hearing 05/02/2026 Date Of Pronouncement 05/02/2026

For Appellant: Shri Parikshit Agarwal, CAFor Respondent: Ms. Monika Singh, CIT DR
Section 14Section 143(3)Section 14ASection 263Section 32Section 36(1)Section 40A(2)(b)Section 5Section 68

issues raised as above. We are thus of the opinion that the order of the assessing officer does not suffer from lack of enquiry, rendering the order erroneous in so far as it is prejudicial to the interests of the revenue. We are therefore, compelled to say that the assumption