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2020 (10) TMI 1051 - AT - Income TaxRevision u/s 263 - show cause notice issued by Ld. Pr.CIT relating to admissibility of agriculture income - HELD THAT:- Assessee as admitting the fact that this issue was not examined by Ld. A.O and Ld. CIT(A) has rightly directed to examine this issue to the Ld. A.O. However direction of Ld. Pr. CIT to the Ld. A.O for framing denovo assessment will not be justified since the additions made in the assessment proceedings u/s 143(3) of the Act has travelled up to the Tribunal, Indore Bench and the additions so made on account of lease rent and disallowance of corporate expenses have been deleted by the Tribunal. On going through the order of Tribunal, Indore Bench in assessee’s own case, we find sufficient merit in the contention made the assessee and are of the considered view that impugned order u/s 263 of the Act dated 26.3.2019 needs to be modified and the direction of Ld. Pr.CIT to the Ld. A.O should be restricted only to the extent of examining the issue of admissibility of agriculture income and not to other issues already dealt by the Ld. A.O - Appeal of the assessee decided partly.
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