Section 263 revision not valid for duly explained cash payment exceeding threshold limit to AO with documents

PCIT Vs Shukla Dairy Pvt. Ltd. (Gujarat High Court) We note that during the assessment proceedings, assesses had submitted before assessing officer (AO), the cash payment register and explained each of the item of proposed addition as per show cause notice of assessing officer. The cash payment register, which is placed at paper book page nos, 22 to 27, wherein payment to the tune of Rs. 1,82,18,581/- has been explained to the assessing officer. The assessing officer, having gone through the cash payment register and explanation of each item, did not make the addition. Therefore, we note that ...