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2021 (3) TMI 217 - AT - Income TaxRevision u/s 263 - addition u/s 68 - HELD THAT:- In the case on hand, the Assessing Officer considered the specific directions given by the ld. CIT(A] in his order u/s. 263 of the Act dt. 23/08/2016 and based on the same had issued questionnaires to the assessee company which is in Annexure-A of the assessment order. Summons were issued u/s. 131 of the Act to the directors of the share holding company M/s. Lakshmi Dealmark Private Limited. The actions taken in compliance with the directions given by the ld. Pr. CIT are given at page 5 to 7 of the assessment order. A perusal of the same demonstrates that the directions were carried out. This is not a case of non-applicability of mind or non-verification. The Assessing Officer has taken a possible view. When the Assessing Officer follows the direction of the Ld. Pr. CIT, in his order passed u/s. 263 of the Act, no revision can be done u/s. 263 of the Act on the ground that the Assessing Officer has not travelled beyond these directions. We have to necessarily hold that the exercise of the revisionary powers by the Ld. Pr. CIT u/s. 263 is bad in law. Hence, we quash the same.
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