Completion of revisionary proceeding within short span of 12 days unjustified: Matter restored back

Dineshbhai Dahyabhai Patel Vs DCIT (ITAT Ahmedabad) ITAT Ahmedabad held that the entire proceedings under Section 263 of the Act were initiated and completed by the PCIT within a period of only 12 days without pointing out reason for lack of enquiry unjustified. Accordingly, matter restored back. Facts- The assessment of the assessee was reopened u/s. 147 and finalized on December 2, 2019, resulting in a revised total income of Rs. 67,06,230/-. This revision included an addition of Rs. 1,56,122/- under section 56(2)(vii) and Rs. 11,43,895/- attributed to short-term capital gains. During the re...