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2022 (3) TMI 258 - DELHI HIGH COURTRevision u/s 263 by CIT - Unaccounted Income - AO had passed the original assessment order without making the required enquiry for verifying the claims made by the assessee - as per ITAT exercise of jurisdiction by the CIT (Exemptions) under Section 263 of the Act was not warranted in the present case - HELD THAT:- This Court is in agreement with the findings recorded by the ITAT that since the total receipts of fees had been disclosed in the income and expenditure account, the same cannot be considered as unaccounted income in the hands of the assessee. This Court is further of the view that the ITAT has correctly held that the Assessing Officer did not make any addition against the assessee on account of interest as well as cost of acquisition because the same were considered and added in the original assessment. In any event, it is settled law that an appeal u/s 260A of the Act is to be entertained only when it directly and substantially affects the rights of the parties or is not free from difficulty or call for discussion of alternative views or the factual finding is perverse. It is further settled law that any interference with the finding of the fact is not warranted if it involves re-appreciation of evidence. Thus the factual findings of the ITAT are clear and cogent.
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