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2022 (5) TMI 669 - AT - Income TaxRevision u/s 263 - Assessment u/s 153A - addition of unaccounted receipts found in 15 red colored notebooks - Reference of relevant seized documents - HELD THAT:- AO has made total addition of unaccounted receipts found in 15 red colored notebooks was already made in A.Y. 2011-12. The initiation of 263 proceedings based on the invalidation of manual return filed by the assessee u/s. 153C is not proper, considering the fact that same income cannot be added in two Assessment Years. Therefore, we are in agreement with the submissions of the Ld. AR. Accordingly, we are inclined to set-aside the order passed u/s. 263 of the Act, hence, grounds raised by the assessee in this regard is allowed.
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