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Because of the meticulous keeping of cash book by a credit co-operative society in (2023] 32 ITR (Trib)-OL 378 (ITAT[Bang]) it escaped further inquiry and fresh assessment otherwise directed by the commissioner with reference to deposit of specified bank notes during demonetisation period. The AO in this case has done proper verification of the details of cash deposited and has given a clear finding with respect to the same.


The PCIT in his order however stated that the AO ought to have conducted further enquiry to check whether the deposits satisfied the test of section 68 which according to the Court was not the right reason for exercising the revisionary powers, as the error envisaged by section 263 did not depend on possibility as a guess work, but should be actually an error either of fact or of law. 

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