Hard work beats talent when talent does not work hard

S.263 – Ex-parte revision order u/s 263 of the Act passed within a short span of 12 days from the date of issuance of show cause notice u/s 263 of the Act despite the fact that more than one year’s time was available with the PCIT for passing such revision order is not tenable in the eye of law. In addition to showing ‘undue haste’ in passing the revision order, the PCIT had also not pointed out as to how there was lack of inquiry on the part of AO. Even the observation with respect to cash payment in excess of Rs.20,000/- in a single day for making disallowance u/s 40A(3) of the Act (i.e. subject matter of revision u/s 263 of the Act) was factually incorrect. Under such circumstances, the matter was restored to the file of the PCIT.