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“lack of inquiry”

Rectification & RevisionSection 263Section 2631,087 judgments

The decision most relied on for lack of inquiry is CIT v. Gabriel India Ltd. (203 ITR 108), cited in 990 judgments on BharatTax.

Leading authorities on lack of inquiry

CIT v. Gabriel India Ltd.
203 ITR 108 · 1993 · High Court
990
citing judgments

The Commissioner cannot revise an assessment order under Section 263 merely because they hold a different opinion or believe a deeper inquiry was warranted if the Assessing Officer has applied their mind and conducted some inquiry. Revision under Section 263 is permissible only in cases of a complete lack of inquiry or non-application of mind by the Assessing Officer, not for merely inadequate inquiry.

CIT v. Orissa Corporation Pvt. Ltd.
159 ITR 78 · 1986 · Supreme Court
897
citing judgments

When an assessee provides the identity and address of a creditor or investor for a cash credit or share capital under Section 68, the burden shifts to the Department to establish lack of genuineness or creditworthiness, requiring it to conduct further inquiries; mere non-compliance by third parties to summons cannot be the sole basis for an adverse inference against the assessee.

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.

Gee Vee Enterprises v. Addl. CIT
99 ITR 375 · 1975 · High Court
543
citing judgments

An assessment order is erroneous and prejudicial to the interest of revenue if the Assessing Officer fails to make proper inquiries before accepting the assessee's statements or claims. The Commissioner can revise such an order under Section 263 without conducting further inquiries himself.

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 inquiry

DCIT, New Delhi vs. M/S. Saamag Infrastructure Ltd., New Delhi

In the result, the Revenue’s appeal stand dismissed

ITA 2600/DEL/2014[2007-08]Status: DisposedITAT Delhi08 Jul 2019AY 2007-08

Bench: Shri H.S. Sidhu & Shri B.R.R. Kumaray 2006-07

For Appellant: Sh. M.P. RASTOGI, ADVFor Respondent: Sh. S.S. RANA, CIT(DR)
Section 132Section 132(1)Section 142(1)Section 143(2)Section 143(3)Section 153ASection 2(22)(e)Section 69C

conduct proper inquiry shifts to Commissioner (Appeals) and Tribunal and they cannot simply delete addition made by Assessing Officer on ground of lack of inquiry 3- ACIT VS Mohar Sinah (16 taxmann.com 37. 49 SOT 129. 137 TTJ 654) (Copy Enclosed) where Hon’ble Jodhpur High Court held that where

DCIT, New Delhi vs. M/S. Saamag Construction Ltd., New Delhi

In the result, the Revenue’s appeal stand dismissed

ITA 2599/DEL/2014[2006-07]Status: DisposedITAT Delhi08 Jul 2019AY 2006-07

Bench: Shri H.S. Sidhu & Shri B.R.R. Kumaray 2006-07

For Appellant: Sh. M.P. RASTOGI, ADVFor Respondent: Sh. S.S. RANA, CIT(DR)
Section 132Section 132(1)Section 142(1)Section 143(2)Section 143(3)Section 153ASection 2(22)(e)Section 69C

conduct proper inquiry shifts to Commissioner (Appeals) and Tribunal and they cannot simply delete addition made by Assessing Officer on ground of lack of inquiry 3- ACIT VS Mohar Sinah (16 taxmann.com 37. 49 SOT 129. 137 TTJ 654) (Copy Enclosed) where Hon’ble Jodhpur High Court held that where

M/S. Dwarkadhis Buildwell Pvt. Ltd., Bhiwani vs. CIT, Hisar

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

ITA 3097/DEL/2014[2006-07]Status: DisposedITAT Delhi01 Jul 2019AY 2006-07

Bench: Sh. R. K. Panda & Sh. Kuldip Singhassessment Year: 2006-07 Dwarkadhis Buildwell Pvt. Ltd Cit C/O N. K. Jain, Advocate Naya Vs Hisar Bazar, Bhiwani Pan No. Aaccd1951E (Appellant) (Respondent) Appellant By Shri Naveen Gupta Ca Shri Ashu Goyal, Ca Sh. Ashok Kumar Jain, Ca Respondent By Ms. Nidhi Srivastava, Cit Dr Date Of Hearing: 16/04/2019 Date Of Pronouncement: 01/07/2019 Order

Section 133ASection 143Section 143(3)Section 263

Hisar does not take into account validity of the jurisdiction assumed by Ld AO as per law and talks about only lack of inquiry and investigation on merits then order passed U/s 263 without setting aside the proceedings initiated U/s 147 dropped by Ld AO by stating in the order

M/S.True Value Steels, Mumbai vs. Income Tax Officer-29(3)(2), Mumbai

In the result, the appeal of the assessee is hereby ordered to be allowed

ITA 998/MUM/2019[2011-12]Status: DisposedITAT Mumbai26 Jun 2019AY 2011-12
For Appellant: Shri Bhadresh DoshiFor Respondent: Shri R. Manjunatha Swamy
Section 143(3)Section 147Section 263

justified. On this point, we find enough potency in the rebuttal provided by the learned representative which was to the effect that the lack of inquiry by the Assessing Officer was not the basis formulated by the Commissioner to invoke the jurisdiction u/s. 263 of the Act. Therefore

Dharampal Contractor Hot Mix Plant, Mansa vs. The Pr. Commissioner of Income Tax, Bathinda

In the result, the appeal of the assessee is allowed

ITA 211/ASR/2017[2012-13]Status: DisposedITAT Amritsar14 Jun 2019AY 2012-13
For Appellant: Shri. P. N. Arora, AdvFor Respondent: Smt. Parwinder Kaur, DR
Section 143(1)Section 143(3)Section 263Section 40A(3)

Assessing Officer ought to have made further inquiries in respect of this issue. Thus, we find that it is not the case of lack of inquiry by the ITA No.211/Asr./2017 7 Dharampal Contractor Hot Mix Plant Assessing Officer. The Ld. Pr. CIT could not point out any error

DCIT, New Delhi vs. M/S. Bhaijee Commodities Pvt. Ltd., New Delhi

In the result, the Appeal of the Revenue stands dismissed

ITA 5323/DEL/2015[2012-13]Status: DisposedITAT Delhi13 Jun 2019AY 2012-13

Bench: Shri H.S. Sidhu & Shri B.R.R. Kumaray 2012-13

For Appellant: Sh. R.S. Singhvi, Adv. &For Respondent: Sh. N.K. Bansal, Sr. DR
Section 131Section 133(6)Section 142(1)Section 143(2)Section 143(3)Section 14ASection 68

fall in the second category and are more in line with facts of Lovely Exports (P) Ltd. (supra). There was a clear lack of inquiry on 10 the part of the Assessing Officer once the assessee had furnished all the material which we have already referred to above. In such

Futuristic Sales Pvt. Ltd., New Delhi vs. Prcit (Central), Gurugram

In the result, the appeal filed by the assessee in ITA No

ITA 1043/DEL/2019[2009-10]Status: DisposedITAT Delhi12 Jun 2019AY 2009-10

Bench: Shri N.K. Billaiya & Shri Sudhanshu Srivastava[A.Y 2009-10] M/S Futuristic Sales [P] Ltd Vs. The Pr. C.I.T Flat No. 97, Sfs, First Floor Central Ashok Vihar, Phase – Iv Gurgaon New Delhi Pan No: Aaacf 6597 N [Appellant] [Respondent]

For Appellant: Shri Gautam Jain, AdvFor Respondent: Ms. Nidhi Srivastava, CIT-DR
Section 132Section 143(1)Section 148Section 263

revenue expenditure. Learned counsel for the assessee is right in his submission that one has to keep in mind the distinction between "lack of inquiry" and "inadequate inquiry". If there was any inquiry, even inadequate that would not by itself give occasion to the CIT to pass orders under ... merely because he has different opinion in the matter. It is only in cases of "lack of inquiry" that such a course of action would be open”. 24. Considering the facts of the case in totality from all possible angles, we failed to persuade ourselves to accept the contention

ITO 12(3)(3), Mumbai vs. Lucas Meyer Industries, Mumbai

In the result, appeal filed by the revenue is allowed, for statistical

ITA 3645/MUM/2017[2008-09]Status: DisposedITAT Mumbai24 May 2019AY 2008-09

Bench: Shri Sandeep Gosain () & Shri G Manjunatha () Ito-12(3)(3), Mumbai Vs M/S Lucas Meyer Industries Pvt Ltd 205/D, Veena Nagar, Chincholi Road Malad W), Mumbai 400 064 Pan : Aaacl6818N Appellant Respondednt

Section 133(6)Section 142(1)Section 143(1)Section 143(2)Section 143(3)Section 147Section 148Section 68

fall in the second category and are more in tine with facts of Lovely Exports (P) Ltd. (supra). There was a clear lack of inquiry on the part of the assessing officer once the assessee had furnished all the material which we have already referred to above. In such

Ankush Garg, Rohtak vs. CIT, Rohtak

In the result, both the appeals of the assessee are dismissed

ITA 2287/DEL/2015[2010-11]Status: DisposedITAT Delhi21 May 2019AY 2010-11

Bench: : Shri Amit Shukla & Shri L.P. Sahu

Section 143(3)Section 263

merely accepted the assessee's explanation on various issues without proper inquiry then the same would come within the ambit of 'lack of inquiry' and not 'inadequate inquiry' • Deepak Maurya ITA 4271/Del/14 A.Y 2011-12. (Copy enclosed) In the light of the above, the Hon'ble Bench may kindly dismiss

Morakhia Metal & Alloys Pvt.Ltd, Ahmedabad vs. The ACIT, Circle-4, Ahmedabad

In the result, the appeal is dismissed

ITA 1113/AHD/2016[2011-12]Status: DisposedITAT Ahmedabad24 Apr 2019AY 2011-12
Section 143(3)Section 145ASection 263

Year : 2011-12 Page 2 of 3 issue on which the revision proceedings were done and the assessment order was set aside, was lack of inquiry with respect to valuation of stock in the context of requirements under section 145A. It is evident from the following observations in the impugned ... paragraph 3 of the impugned order. Admittedly, however, all these aspects were not at all examined at the assessment stage. It is this lack of inquiries which has rendered the assessment order erroneous and prejudicial to the interests of the revenue. As regards learned counsel’s reliance

Sh. Sanjeev Singh, Karnal vs. Pr. CIT, Karnal

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

ITA 1781/DEL/2016[2011-12]Status: DisposedITAT Delhi24 Apr 2019AY 2011-12

Bench: Shri R.K. Panda & Ms Suchitra Kambleassessment Year: 2011-12 Sanjeev Singh, Vs Pr. Cit, 861, Sector-9 U.E, Karnal. Karnal. Pan: Chkps0618H (Appellant) (Respondent) Assessee By : Dr. Rakesh Gupta, Shri Somil Aggarwal & Sobhit Revenue By : Shri Kanwaljit Singh, Cit, Dr Date Of Hearing : 13.02.2019 Date Of Pronouncement : 24.04.2019 Order Per R.K. Panda, Am: This Appeal Filed By The Assessee Is Directed Against The Order Dated 3Rd February, 2016 Passed U/S 263(1) Of The It Act, 1961 By The Pcit, Karnal, Relating To Assessment Year 2011-12. 2. Facts Of The Case, In Brief, Are That The Assessee Is An Individual & Filed His Return Of Income On 6Th July, 2011 Declaring Total Income Of Rs.1,58,105/- & Agricultural Income Of Rs.5 Lakhs. The Assessing Officer Completed The Assessment U/S 143(3) On 10Th January, 2014 Determining The Total Income Of The Assessee At Rs.6,30,545/- & Agricultural Income Of Rs.5 Lakhs. Subsequently, The Ld.Cit Issued

For Appellant: Dr. Rakesh GuptaFor Respondent: Shri Kanwaljit Singh, CIT, DR
Section 143(3)Section 263Section 263(1)

submitted that the Hon'ble High Court in the said decision has held that in cases where there is inadequate inquiry, but, lack of inquiry, the CIT may give and record a finding that the order/inquiry is erroneous. This can happen if an inquiry and verification is conducted

Sheth Commercial Co., Kolkata vs. CIT-14 Kolkata, Kolkata

Appeal is allowed

ITA 1406/KOL/2017[2012-13]Status: FixedITAT Kolkata16 Apr 2019AY 2012-13

Bench: Shri S.S.Godara & Dr. A.L. Sainiassessment Year :2012-13 Sheth Commercial Co. V/S. Pr. Cit-14, C/O D.J. Shah & Co. 3, Government Place, Kalyan Bhavan, 2 Elgin Kolkata-700001 Road, Kolkata-700020 [Pan No.Aakfs 409 H] .. अपीलाथ" /Appellant ""यथ"/Respondent Shri Miraj D Shah, Advocate अपीलाथ" क" ओर से/By Appellant Shri P.K. Shrhari, Cit-Dr ""यथ" क" ओर से/By Respondent 13-03-2019 सुनवाई क" तार"ख/Date Of Hearing 16-04-2019 घोषणा क" तार"ख/Date Of Pronouncement आदेश /O R D E R Per S.S.Godara:- This Assessee’S Appeal For Assessment Year 2012-13 Arises Against The Principal Commissioner Of Income Tax-14, Kolkata’S Order Dated 20.03.2017 Directing The Assessing Officer To Frame Afresh Assessment After Setting Aside The Regular One Framed Dated 23.03.2015 In Exercising Revision Jurisdiction Vested U/S 263 Of The Income Tax Act, 1961 (Hereinafter Referred To As ‘The Act’). We Have Heard Shri Miraj D Shah Learned Authorized Representative For Assessee & Shri P.K.Srihari, Cit/Dr Appearing At Revenue’S Behest. Case File Perused. 2. It Transpires During The Course Of Hearing That The Assessee’S Pleading Challenge Correctness Of The Pcit’S Order Revising The Regular Assessment In Issue Framed By The Assessing Officer On 06.07.2016 With Directions To Frame

Section 1Section 263Section 35(1)(c)

Expenditure. Learned counsel for the assessee s right in his submission that one has to keep in mind the distinction between “lack of inquiry” and inadequate inquiry”. If there was any inquiry, even inadequate that would not by itself give occasion to the Commissioner to pass orders under section ... merely because he has a different opinion in the matter. It is only in cases of “lack of inquiry” that such a course of action would be open. In Gabriel India Ltd. [1993] 203 ITR 108 (Bom), law on this aspect was discussed in the following manner (page 113): ‘... From

Sh. Asrar Ahmed, New Delhi vs. Pr. CIT, Ghaziabad

In the result, the appeal of the assessee is allowed

ITA 3279/DEL/2017[2010-11]Status: DisposedITAT Delhi15 Apr 2019AY 2010-11

Bench: Shri Amit Shukla & Shri O.P. Kant

For Appellant: Dr. Rakesh Gupta, Adv. & Shri SomilFor Respondent: Shri Sanjay Goel, CIT-D.R
Section 148Section 263

quashed. 10. On the issue of cash deposit also, he submitted that, nowhere the ld. PCIT has held that there was any lack of inquiry by the Assessing Officer or proper inquiry has not been done. From the observation made at page 9 of the 10 I.T.A. No.3279/DEL/2017 impugned order ... case same are not properly explained then it should be treated as unexplained income. Thus, here it not a case of lack of inquiry or verification of material placed on record but to re- verify once again which cannot be the purpose for invoking revisionary jurisdiction u/s.263. Thus impugned order

Bagrrys India Ltd., New Delhi vs. Pr.CIT- 2, New Delhi

Appeal of the assessee is allowed

ITA 3785/DEL/2018[2013-14]Status: DisposedITAT Delhi29 Mar 2019AY 2013-14

Bench: Shri Amit Shukla & Shri O.P. Kant

For Appellant: Shri V.K. Bindal, Adv. & Ms. SweetyFor Respondent: Shri Sanjay Goel, CIT-D.R
Section 115JSection 139Section 143(3)Section 263Section 80I

laws would reach after due appreciation of such material. If this component is missing, it will always be a case of lack of inquiry and not inadequate inquiry.” 24 I.T.A. No.3785/DEL/2018 Decision 11. We have heard the rival submissions and also perused the relevant findings given in the impugned orders

Rajesh Kumar, Hisar vs. CIT, Hisar

In the result, the appeal of the assessee is dismissed

ITA 3337/DEL/2013[2008-09]Status: DisposedITAT Delhi29 Mar 2019AY 2008-09

Bench: Shri Bhavnesh Saini & Shri O.P. Kantassessment Year: 2008-09 Shri Rajesh Kumar, Vs. Cit, 1931, Gate No. 2, Behind Hisar M.G. Road, Hisar Pan :Aohpk1201L (Appellant) (Respondent) Appellant By Shri Manoj Kumar, Adv. Respondent By Smt. Sulekha Verma, Cit(Dr)

Section 143(3)Section 263Section 263(1)

case of CIT Vs Sunbeam Auto Limited (supra) relied upon by the assessee, it has been held that “there is a difference between “lack of Inquiry and inadequate enquiry” and if there is an enquiry, even inadequate, that would not by itself give occasion to the CIT to pass orders

Smt. Parulben Rajubhai Trivedi, Ahmedabad vs. ITO, Ward-6(1)(3), Ahmedabad

In the result, the appeal of the assessee is allowed

ITA 1308/AHD/2018[2013-14]Status: DisposedITAT Ahmedabad28 Mar 2019AY 2013-14

Bench: Shri Pradip Kumar Kedia & Shri Mahavir Prasad, Judicial Memebr आयकर अपील सं./I.T.A. No. 1308/Ahd/2018 ("नधा"रण वष" / Assessment Year : 2013-14)

For Respondent: Shri O. P. Sharma, CIT.D.R
Section 143(3)Section 263

Thus, clearly, the case made out by the Pr.CIT is purportedly inadequacy in the extent of inquiry but not a case of total lack of inquiry with lenders. It is evolved by judicial precedents that in the case of inadequacy in inquiry (unlike lack of inquiry) on a point

Sterling Addlife India Private Ltd., Ahmedabad vs. Pr. CIT-4, Ahmedabad

In the result, the appeal of the assessee is partly allowed

ITA 967/AHD/2018[2013-14]Status: DisposedITAT Ahmedabad27 Mar 2019AY 2013-14

Bench: Shri Waseem Ahmed & Ms. Madhumita Royआयकर अपील सं./Ita No.967/Ahd/2018 ("नधा"रण वष"/Assessment Year : 2013-14) बनाम/ Sterling Addlife India The Pr.Cit-4 Pvt.Ltd. Ahmedabad Vs. Sterling Hospital Buildings Off Gurukul Road Memnagar Ahmedabad-380 052 "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aadca 0897 M (अपीलाथ"/Appellant) (""यथ" / Respondent) .. अपीलाथ" ओर से/ Appellant By : Shri Dinal Shah & A.C.Shah, Ars ""यथ" क" ओर से/Respondent By: Shri Mahesh Shah, Cit-Dr सुनवाई क" तार"ख/ Date Of Hearing 28/01/2019 घोषणा क" तार"ख /Date Of Pronouncement 27/03/2019 आदेश / O R D E R Per Waseem Ahmed: The Captioned Appeal Has Been Filed At The Instance Of The Assessee Against The Order Of The Commissioner Of Income Tax–4, Ahmedabad [Cit In Short] Dated 28/03/2018 Relevant To Assessment Year (Ay) 2013-14. 2. The Assessee Has Raised The Following Grounds Of Appeal:-

For Appellant: Shri Dinal Shah & A.C.Shah, ArsFor Respondent: Shri Mahesh Shah, CIT-DR
Section 143(3)Section 14ASection 263

explanation. It is held that in adequacy of inquiry cannot be taken as a recourse under this explanation. There is a distinction between lack of inquiry and inadequate inquiry. It is only in case of lack of inquiry, CIT is empowered to exercise his revisional powers u/s. 263. Please refer

Philips India Ltd., Kolkata vs. PCIT-IV, Kolkata

In the result, appeal of the assessee is dismissed

ITA 1142/KOL/2016[2009-2010]Status: DisposedITAT Kolkata27 Mar 2019AY 2009-2010

Bench: Sri J. Sudhakar Reddy & Sri S.S. Viswanethra Ravi] I.T.A. No. 1142/Kol/2016 Assessment Year: 2009-10 Philips India Limited..........……………………………………....………………..…………………….….Appellant Earlier Known As Philips Electronics India Limited 7 No. Justice Chandra Madhab Road Kolkata – 700 020 [Pan : Aabcp 9487 A] Principal Commissioner Of Income Tax - Iv, Kolkata…….............…....................…...Respondent Appearances By: Shri P.J. Pardiwala, Sr. Advocate & Shri Navneet Misra, Advocate, Appeared On Behalf Of The Assessee. Shri Robin Choudhury, Addl. Cit D/R, Appearing On Behalf Of The Revenue. Date Of Concluding The Hearing : January 10Th, 2019 Date Of Pronouncing The Order : March 27Th, 2019 O R D E R Per J. Sudhakar Reddy :-

Section 143(3)Section 263Section 32

Commissioner to pass orders under Sec.263 merely because he has a different opinion in the matter; that it is only in cases of lack of inquiry that such a course of action would be open; that an assessment order made by the Income Tax Officer cannot be branded as erroneous ... Commissioner to pass orders under Sec.263 merely because he has a different opinion in the matter; that it is only in cases of lack of inquiry that such a course of action would be open; that an assessment order made by the Income Tax Officer cannot be branded as erroneous

Grandhi Subhakar, Visakhapatnam vs. Income Tax Officer, Ward -3(3), Visakhapatnam

In the result, appeal filed by the assessee is dismissed

ITA 206/VIZ/2018[2013-14]Status: DisposedITAT Visakhapatnam22 Mar 2019AY 2013-14

Bench: Shri V. Durga Rao, Hon’Ble & Shri D.S. Sunder Singh, Hon’Blegrandhi Subhakar, Vs. Ito, Ward-3(3), Flat No. 201, D.No.9-19- Visakhapatnam. 41/3(2), Bachina Residency, Sbi Colony, Visakhapatnam. Pan No. Aevpg 1445 A (Appellant) (Respondent) Assessee By : Shri G.V.N. Hari – Advocate. Department By : Shri D.K. Sonawal – Cit Dr Date Of Hearing : 18/03/2019. Date Of Pronouncement : 22/03/2019. O R D E R Per V. Durga Raothis Appeal By The Assessee Is Directed Against The Order Of Principal Commissioner Of Income Tax-1, Visakhapatnam, Dated 30/03/2013 For The Assessment Year 2013-14. 2. The Assessee Has Filed Revised Grounds Of Appeal Which Are As Follows:- “1. The Order Of The Learned Pr. Commissioner Of Income Tax-1, Visakhapatnam Is Contrary To The Facts & Also The Law Applicable To The Facts Of The Case. 2. The Learned Pr. Commissioner Of Income Tax Is Not Justified In Assuming Jurisdiction U/S 263 Of The Act In As Much As The Assessment Order Dated 28.01.2016 U/S 143(3) Of The Act Is Neither Erroneous Nor Prejudicial To (Grandhi Subhakar)

For Appellant: Shri G.V.N. Hari – AdvocateFor Respondent: Shri D.K. Sonawal – CIT DR
Section 143(3)Section 263

have appreciated that the assessing officer initiated enquiries in respect of the above issues and as such it is not a case of 'lack of inquiry 'to enable the learned Pr. Commissioner of Income Tax to invoke the provisions of S.263. 5. Any other ground that may be urged

Dabur Invest Corp, New Delhi vs. Prcit-16, New Delhi

In the result, the appeals of the assessee in ITA Nos

ITA 1764/DEL/2018[2014-15]Status: DisposedITAT Delhi11 Mar 2019AY 2014-15

Bench: Shri N.K. Billaiya & Ms. Suchitra Kamble[A.Y 2013-14] & [A.Y 2014-15]

For Appellant: Shri M.P. Rastogi, AdvFor Respondent: Shri G.C. Srivastava, Sr Adv
Section 263

1 IN THE INCOME TAX APPELLATE TRIBUNAL, DELHI ‘B’ BENCH, NEW DELHI BEFORE SHRI N.K. BILLAIYA, ACCOUNTANT MEMBER, AND MS