TMI Blog2021 (3) TMI 440X X X X Extracts X X X X X X X X Extracts X X X X ..... ndent has proposed to revise the assessment order at Ext.P2 and for that purpose, objections of the petitioner are invited. Opportunity of hearing is also to be granted to the petitioner vide show- cause notice at Ext.P4. Thus the petitioner shall have full opportunity to put up its case before the revisional authority. At this stage, it cannot be said that the 2nd respondent revisional authority is biased and is bent upon to decide the matter adversly. Official acts are regularly done in wise principle of law and hence without there being any material on record, it cannot be said that issuance of show-cause notice reflects nothing but a biased attitude of the 2 nd respondent. This Court hope and expect that the 2nd respondent shall determi ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... s that the learned Tribunal was pleased to direct the assessing officer to get the valuation report for the impugned property from the DVO and to decide the issue afresh. My attention was drawn to the order of the learned ITAT at Ext.P1. With this, it is argued that the order of the Income Tax Appellate Commissioner was duly complied and the assessment order at Ext.P2 was passed on 06/05/2020 by the Income Tax Officer by considering the report of the DVO. The learned counsel for the petitioner submits that without there being any reason, the 2nd respondent-Principal Commissioner of Income Tax has decided to initiate suo motu revision by contending that the order of the Income Tax Officer is erroneous as it is prejudicial to the interest of ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... neer vide letter dated 19.05.2020. 5. The learned counsel for the petitioner submits that the said report dated 19.05.2020 was not before the Assessment Officer who has passed the Assessment order on 06.05.2020, and as such it cannot be relied upon for exercising revisional powers. However, though the said report might not be before the assessing officer, the Principal Commissioner can certainly use such report for exercising suo moto revisional jurisdiction. The matter is at the stage of show-cause notice. The 2nd respondent has proposed to revise the assessment order at Ext.P2 and for that purpose, objections of the petitioner are invited. Opportunity of hearing is also to be granted to the petitioner vide show- cause notice at Ext.P4. ..... X X X X Extracts X X X X X X X X Extracts X X X X
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