Revisional power cannot be exercised without indicating possible & prospective path of enquiry

Shivalic Academy Society Vs CIT (E) (ITAT Delhi)

Settled position of law is that for the purpose of exercising jurisdiction u./s. 263 of the Act, the conclusion that the order of the AO is erroneous and prejudicial to the interest of the revenue has to be preceded by some minimal enquiry. If the Revisional authority is of the view that the AO did not undertake any enquiry, it becomes incumbent on the Revisional Authority to conduct such enquiry. If the Revisional Authority does not conduct such basic exercise then he is not justified in setting aside th

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