Merely asking a question and not carrying it further can be a case of non-enquiry requiring issue of notice u/s 263 vide (2017) 8ITR-OL 506.
In this case the assessee in his reply did not address one of the point in the questionnaire seeking information on method of valuation of unlisted shares which prompted the Commissioner to open up the case for a revision.
As a matter of fact it is expected of the AO to take stock of questions and issue a final show cause for any unanswered questions before completing assessment rather than pushing the taxpayer in revision imbroglio subsequently. Any failure to ask for unanswered questions must be reckoned as similar to considered and drop action to resist litigation.
