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2022 (4) TMI 1057 - AT - Income TaxRevision u/s 263 - Reopening of assessment u/s 147 - bad debts claim u/s. 36(1)(vii) - HELD THAT:- As relying on THE CITY COOPERATIVE BANK LTD.[2017 (9) TMI 1982 - ITAT MUMBAI] we are inclined to allow the claim of the assessee. Moreover, the assessment was originally assessed u/s. 143(3) of the Act and subsequently reopened to examine the same issue. After verification, the Assessing Officer has accepted the contention of the assessee. Once again Ld. Pr.CIT raised the same issue and directs the Assessing Officer to verify the same once again after giving opportunity of being heard to the assessee. Pr.CIT cannot impose his views on the issue which was verified twice and respective Assessing Officer’s has taken their view. Considering the sequence of events in our view Ld. Pr.CIT has no jurisdiction to interfere with the completed proceedings otherwise, there is no end to the assessment proceedings. Therefore, the revision order passed u/s.263 is accordingly, set aside. Grounds raised by the assessee are allowed.
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