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2021 (12) TMI 498 - ITAT DELHIRevision u/s 263 by CIT - disproportionate purchase of structural steel - HELD THAT:- Show cause notice related to the purchases was for the entire purchases and not for the specific purchase. In fact the assessee’s submissions to the show cause notice revealed that the details were presented before the Assessing Officer as there were specific purchases and the same was properly taken into account by the Assessing Officer. Thus, Section 263 of the Act does not attract, as the Pr. CIT has taken divergent view on particular issue which is not contemplated while invoking the provisions of Section 263 of the Act, hence appeal of the assessee is allowed.
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