Suspicions of department cannot be base for revisionary proceedings

Trivikram Singh Toor Vs PCIT (ITAT Chandigarh)

ITAT Chandigarh held that suspicions entertained by the Revenue cannot be the basis of unsettling the valid order and hence revisionary order proceeded entirely on presumptions, conjectures and surmises is liable to be quashed.

Facts-

The Assessing Officer in the facts of the present case made an addition of Rs.2,15,847/- to the returned income of the assessee vide order passed u/s 143(3) r.w. Section 147. The said addition was made by way of disallowing the loss from derivatives and adding it back to the income of the assessee.

This order was subjected to the Revisionary Powers of the PCIT u/s 263 by the order dated 21.03.2021.

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