No revision u/s 263 merely because CIT had different opinion in the matter

Arul Industries Vs ACIT (Madras High Court) Conclusion: Where AO had made inquiry and formed view, though inquiry may be inadequate, revision u/s 263 was not justified merely because CIT had different opinion in the matter. Held: Assessee, a partnership firm was engaged in manufacture and sale of kitchen utensils had filed return for AY 2007-08 declaring NIL income. Scrutiny assessment u/s 143(3) was completed on 15.12.2009, determining income at ₹47.89 lakh (including LTCG ₹12.88 lakh). Post-search (u/s 132 in another group, u/s 133A at assessee’s premises), assessment was redone u/s 14...