Gujarat State Electricity Corporation ... vs The Pr. Cit-1, Vadodara on 8 April, 2025
13. In view of the foregoing discussion, we are of the considered view that
the assessment order is vitiated due to complete absence of inquiry on two
material items having a substantial bearing on the determination of taxable
income under the normal provisions of the Act. The explanations and
accounting entries now furnished by the assessee were not subjected to
verification during the original assessment and hence do not cure the error at
the stage of revision. The PCIT was justified in invoking section 263 of the Act
and directing the AO to reframe the assessment after examining the nature
ITA No.572/Ahd/2020
Gujarat State Electricity Corporation Ltd. vs. Pr.CIT-1
Asst. Year : 2015-16
12
and allowability of the impugned items. The revisionary order is valid in law
and does not suffer from any jurisdictional or procedural infirmity.