Emphasizes Assessing Officer’s duty to scrutinize all issues noticed during reassessment proceedings; Upholds revision order

Delhi ITAT upholds the revision order under Section 263 holding the reassessment order as erroneous and prejudicial to the interest of Revenue on the ground that the Assessing Officer failed to examine the source of import of a painting of Rs. 40,45,500/-; ITAT emphasises that in light of Explanation 3 of Section 147, once the Assessing Officer has made the additions on issues for which the satisfaction of escapement of income was recorded and the proceedings were initiated under Section 148, it is the duty of the Assessing Officer to make necessary verification of the other issues which came to his notice subsequently; ITAT notes that the Assessing Officer, based on the information that the source of a painting imported by the Assessee remained unexplained, passed the reassessment order; Further, PCIT invoked Section 263 jurisdiction on the ground that the Assessing Officer failed to enquire about another painting that was imported by the Assessee, thus held the assessment order to be erroneous and prejudicial to the Revenue’s interest; ITAT states that the Assessee himself accepted that the Assessing Officer has not made verification of the second import of painting of Rs. 40,45,500/-, as it was not part of the reasons recorded; Thus, ITAT opines that as per Explanation 3 of Section 147, the Assessing Officer should have examined the source of other imports made; ITAT notes that the Assessing Officer in the present case, has made the addition on account of issue for which the satisfaction was recorded for reopening the assessment, therefore, he has every jurisdiction to examine and verify all the other issues that came before him during the proceedings which the Assessing Officer has failed to do so; Thus ITAT confirms the revision order passed by PCIT holding that non verification of source of the such import make the reassessment order erroneous and prejudicial to the interest of the Revenue. n the result, the appeal of the assessee is dismissed. [In favour of revenue] (Related Assessment year : 2018-19) – [Harsh Vardhan Singh v. PCIT [TS-1634-ITAT-2025(DEL)] – Date of Judgement : 05.12.2025 (ITAT Delhi)]