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2018 (8) TMI 1546 - AT - Income TaxRevision u/s 263 - case of “no enquiry” - non verification of amount shown under “suspense account” - Held that:- CIT has rightly invoked the provisions of section 263 of the Act as Ld.AO failed to make proper enquiry, examination and verifications as warranted for the proper completion of the assessment, with respect to monies shown under the head ‘suspense account’. It is correctly pointed out by Ld.CIT-DR, section 263 has been enacted to empower CIT to exercise power of revision and revise any order passed by Assessing Officer if two cumulative conditions are satisfied, where the order sought to be revised should be erroneous and it should be prejudicial to the interest of revenue. In the facts of the present case, admittedly Assessing Officer at assessment stage has not verified amount shown under “suspense account”. It is very apparent that Assessing Officer has not verified its sources and mode of deposit. In our view this is clear case of “no enquiry” and therefore, Ld.CIT was right in initiating proceedings under section 263 of the Act. Further, it is observed that, Ld.CIT has specifically directed Assessing Officer to restrict examination of transactions in suspense account and taking such examination to its logical conclusion as per law. We therefore do not find any infirmity in order passed by Ld. CIT under section 263 of the Act as there is no injustice that is caused to assessee. - Decided against assessee.
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