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2022 (10) TMI 817 - AT - Income TaxRevision u/s 263 by CIT - Addition u/s 68 - HELD THAT:- We can see that learned AO made proper enquiry and during assessment proceedings, all details such as, i. list of unsecured loan received during the years; ii. list of share holders; iii. Copy of ledger accounts of each share holder. Iv. Copy of ledger accounts of each lender in its books; v. copies of contra confirmation; vi. Copy of bank statement; vii. Copy of bank account; 8. Copy of income tax return alongwith computation of income & ix. Copy of PAN were submitted. We have noticed that Company was formed in 2013 for vitrified files and stated commercial production in 2016. The co-ordinate bench in case of Hitendra A. Nanavati [2010 (10) TMI 1076 - ITAT AHMEDABAD] it has been held that where learned AO was satisfied with explanation of assessee, a change of opinion or view would not enable CIT to exercise jurisdiction u/s 263 of the Act Thus share capital, share application money and unsecured loan in the present case can never be regarded as undisclosed income of the assessee under S.68 of the Act. Thus, we hold that in present case the revision under S.263 of the Act is not permissible. Appeal filed by the Assessee is allowed.
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