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2022 (5) TMI 1414 - PUNJAB AND HARYANA HIGH COURTValidity of Revision u/s 263 - Whether inquiry or verification was not made by the Assessing Officer before passing the order? - HELD THAT:- The contention of Ld. Senior Standing Counsel that the order passed by the Assessing Officer will fall within the ambit of Explanation 2 (a) appended to Section 263 of the Act, cannot be accepted till it is pointed out as to which inquiry or verification was not made by the Assessing Officer before passing the order. Ld. Senior Standing Counsel is not in a position to deny the fact that prior to passing of order under Section 143(3) of the Act, a questionnaire was issued by the Assessing Officer in the course of assessment proceedings to the assessee. The specific issues addressed by the appellant in the present proceedings were part of the questionnaire. Appellant is not in a position to point out as to what are those inquiries or verification which should have been made but have not been made by the Assessing Officer in the present case so as to make the present case fall within Explanation 2 attached to Section 263 - The substantial questions of law sought to be raised of the grounds of appeal are pure questions of fact which have been adequately answered by the Tribunal.
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