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2019 (1) TMI 1211 - HC - Income TaxRevision u/s 263 - high share premium as well as the high closing stock - Held that:- AO had made necessary inquiry/ verification with regard to both the issues namely high share premium as well as the high closing stock. Moreover, as noted this inquiry was done by the AO after having obtained the necessary approval from the Chief Commissioner of Income Tax. Infact this itself is an evidence of application of mind of the AO, followed by notice to the respondent and verification of the response of the respondent. The aforesaid facts while exercising the powers of revision has been completely ignored the CIT. The impugned order of the Tribunal correctly held following the decision of this Court in Gabrial (I) Ltd.(1993 (4) TMI 55 - BOMBAY HIGH COURT) that the Assessment Order dated 3rd July, 2013 cannot be termed erroneous simply because he may have written the order move elaborately or taken a different view on facts (which is not perverse).
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