CIT needs to independently apply his mind prior to invoking revisionary provisions u/s. 263: ITAT Kolkata

Rajesh Kumar Jalan Vs PCIT (ITAT Kolkata) ITAT Kolkata held that CIT has not applied his mind analytically while assuming jurisdiction for taking cognizance under section 263 of the Income Tax Act. Thus, in absence of independent application of mind, invocation of revisionary provisions by CIT unsustainable. Facts- Assessee at the relevant time was engaged in trading of cloth including sarees. AO had received information from Bureau of Investigation, Commercial Taxes, West Bengal during the meeting of REIC held on 23.03.2018. This information exhibits that the assessee had by fraudulent act op...