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2019 (12) TMI 399 - AT - Income TaxPower of revision - scope of assessment under limited scrutiny - Validity of the revision order passed by the ld. PCIT u/s 263 of the Act - HELD THAT:- The Assessing Officer had completed the assessment after making addition of 3,00,000/- treating the gift received from his brother as unexplained cash credit. But it appears that the Assessing Officer had looked into issue of source only to the extent of 41,50,000/- which is apparent consideration paid for the purchase of property. The value adopted for stamp duty purpose is taken as deemed consideration u/s 56(2)(vii) (b) of the Act and this is only deemed provision and there is no occasion for the assessee to explain the source for deemed consideration paid. It is settled position of law that while completing the assessment under limited scrutiny, the Assessing Officer cannot look beyond the issue for which the case was selected for scrutiny. It is beyond the power of the Assessing Officer to look into any other issue which has come to his notice during the course of assessment proceedings. The impugned order passed by the ld. PCIT cannot be sustained in the eyes of law - appeal of assessee allowed.
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