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2022 (10) TMI 230 - ITAT RAJKOTRevision u/s 263 by CIT - Addition u/s 68 - share capital & unsecured loan introduced/raised during the year and the claim of depreciation and additional depreciation - case of the assessee was selected through "CASS" selection for Complete Scrutiny, where the purpose of assessment was to scrutinize the substantial increase in share capital including creditor in the captioned year - HELD THAT:- Assessee was selected through "CASS" selection for Complete Scrutiny, where the purpose of assessment was to scrutinize the substantial increase in share capital including creditor in the captioned year. During the course of assessment proceedings, the Ld. AO made detailed enquiries on this issue & on the issue of claim of depreciation on addition of fixed assets and after consideration of time-to-time written submissions filed by the assessee and documents / evidence placed on record, the Ld. AO accepted the submission and explanation of the assessee. CIT initiated 263 proceedings on the ground that the AO has not made enquiries or verification which should have been made in respect of share capital introduced, unsecured loan raised during the year under consideration and claim of depreciation & investment allowances under section 32AC of the Act. It is not the case of the Pr. CIT that the Ld. AO did not apply his mind to the issue on hand or he had omitted to make enquiries altogether. In the instant set of facts, AO had made detailed enquiries and after consideration of material placed on record, accepted the claim of the assessee. We thus find no error in the order of Ld. AO so as to justify initiation of 263 proceedings by the Ld. Pr. CIT. Ground of appeal raised by the assessee is thus allowed.
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