Section 263 jurisdiction valid on issues not enquired by AO

Sh. Rajeev Goyal Vs PCIT (ITAT Chandigarh) In ITA 149/Chd/2021, in the case of Shri Rajiv Goyal, it has been alleged by the Ld. Pr. CIT that the issue of addition to capital account amounting to Rs. 3,63,458/- on account of compensation received and another issue of an amount of Rs. 2,55,800/- pertaining to property in Meerpur has apparently not been enquired into by the AO. A perusal of the record shows that this allegation of the Ld. Pr. CIT is correct in so far as no query has been raised by the AO on these two issues and neither has the assessee made any submissions either before the AO or...