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2022 (1) TMI 1091 - AT - Income TaxConversion of "limited" scrutiny to a "complete" one - scope of enquiry under 'Limited Scrutiny' - HELD THAT:- The reason of the assessee's "limited" scrutiny herein was regarding the assessee's cash deposit in savings account(s) as more than the turnover only. And that the AO had duly taken note of the fact that the assessee had made huge cash deposits in his OD account whilst sending his proposal to the PCIT There is no material on record which could indicate the assessee to have either declared or explained source of his cash deposits made in the undisclosed bank account concerned. A perusal of the assessment order sufficiently reveals that it was only after the assessee's failure to explain source of his deposits and other issues that the AO sought for PCIT's approval in issue which stood accepted on 22.12.2016. We observe in this factual backdrop that the Assessing Officer's failure, if at all, in issuing notice of "complete" notice to the assessee between 22.12.2016 to 31.12.2016 was only a procedural one only which could not be held to have vitiated the entire assessment proceedings as a non-est one as held in the CIT(A)'s order under challenge. We therefore reverse lower appellate findings to this effect and restore the Revenue's sole substantive ground raised in the instant appeal back to the Assessing Officer for his afresh factual verification/adjudication qua all the issues following subject matter of "complete" scrutiny as per law within three effective opportunities of hearing.
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