AO’s Blind Acceptance of Past Savings justifies Section 263 Revision

Gora Bai Sahu Vs ITO (ITAT Agra)

AO’s Lapse on Source Verification Proves Costly: Section 263 Sustained- ITAT Agra Says AO’s Blind Acceptance of Past Savings Not a Possible View

Facts

AIR information revealed purchase of immovable property worth ₹60 lakh jointly by 3 persons; & Assessee’s share was ₹20 lakh. AO reopened the case u/s 147 & completed assessment u/s 143(3) r.w.s.147 on 29.11.2019 at returned income of ₹2,10,500. AO accepted Assessee’s explanation that the ₹20 lakh investment was from “pas

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