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2023 (8) TMI 1435 - AT - Income TaxValidity of Revision u/s 263 - case for selected for limited scrutiny - CIT made addition of income u/s. 2(24)(x) r.w.s. 36(1)(va) of the Act for EPF - as argued since the assessment was a limited scrutiny assessment and the error noted by the PCIT was beyond the scope of limited scrutiny of the AO - HELD THAT:- DR was unable to controvert both the factual contentions of the assessee that the assessment in the present case was a limited scrutiny assessment and the error noted by the PCIT in the assessment order was beyond the scope of limited scrutiny; nor was he able to controvert the proposition of law laid down by the various courts in this regard as pointed out by assessee before us that there cannot be any error in the assessment framed in limited scrutiny on issues which were beyond the scope of limited scrutiny. In view of the above, we are in complete agreement with assessee that the impugned order passed by the ld. PCIT u/s 263 is not sustainable in law, and it is, therefore, directed to be quashed. Appeal of the assessee is allowed.
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