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2022 (6) TMI 948 - AT - Income TaxRevision u/s 263 by CIT - whether there is complete lack of enquiry by the ld. AO while framing assessment? - HELD THAT:- PCIT referred to two transactions, firstly, transfer of Rs. 11,00,000/- to the assessee’s account from M/s. Patra Bastraiaya. Another transaction was of Rs. 27,00,000/- reflecting in the assessee’s bank account received from M/s. Santosh Agency on 14.06.2010. Source and nature of transaction of Rs. 27,00,000/- with M/s. Santosh Agency remained unverified. No verification was done to this effect in the course of assessment. Also the connection between the transaction of Rs. 11,00,000/- with M/s. Patra Bastraiaya and the transaction with M/s. Santosh Agency remained unexamined. We notice that all the above observations made by ld. PCIT in the impugned order were alleged not to have been verified by the ld. AO. The submissions made by the assessee before ld. PCIT appearing in the impugned order are not sufficient to explain the said transactions. No detailed discussion is made in the assessment order also. No paper book has been filed by the assessee to demonstrate that whether ld. AO raised necessary queries/conducted enquiry on the issues referred herein above and whether the assessee had furnished a detailed reply including relevant documents to satisfy the AO. We find no reason to interfere in the finding of ld. PCIT holding the assessment order dated 07.12.2018 u/s 147 r.w.s. 143(3) of the Act as erroneous and prejudicial to the interests of the Revenue and setting aside the same for afresh adjudication. Thus, since a valid jurisdiction has been invoked by ld. PCIT, we confirm the finding in the impugned order and dismiss all the grounds raised by the assessee in the instant appeal. Appeal of the assessee is dismissed.
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