TMI Blog2014 (2) TMI 134X X X X Extracts X X X X X X X X Extracts X X X X ..... ue to the department - The revisional authority cannot substitute its own decision to say that the addition made by the Assessing Officer is insufficient - Relying upon CIT Vs. Satpal Agrawal [2007 (2) TMI 104 - HIGH COURT, PUNJAB AND HARYANA] - no substantial question of law arises for consideration, the assessing officer has assessed the income by making certain addition based on his own opinion ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... d out, the order of Assessing Officer is Annexure A-1. However, invoking the jurisdiction available to him under Section 163, the Commissioner of Income Tax found that the assessment of income done is prejudicial to the interest of revenue, hence set aside the assessment order and remand the matter back to the Assessing Officer. An appeal is filed by the assessee before the Appellate Tribunal and ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... n the books of account, if makes a addition of the income which is sufficient in his opinion to compensate the loss of revenue to the department. The revisional authority cannot substitute its own decision to say that the addition made by the Assessing Officer is insufficient. It is found that until and unless the Assessing Officer has made a mistake in the matter of assessment of income and same ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... an error of law is committed, therefore, no substantial question of law arises for consideration, the assessing officer has assessed the income by making certain addition based on his own opinion and have given cogent reasons for the same. There is nothing to say that the opinion and reason given by the assessing officer is wholly erroneous. If order of the Assessing Officer Annexure A-1 is taken ..... X X X X Extracts X X X X X X X X Extracts X X X X
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