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2022 (11) TMI 417 - AT - Income TaxRevision u/s 263 by CIT - case was selected for scrutiny through CASS - Non examination of issues cash deposits made in the bank account of the assessee during demonetization period - HELD THAT:- Though the case of the Appellant/Assessee was also selected for detailed scrutiny for the reason of high value receipt of cash shown from third parties, in the assessment order there is no discussion in respect of the same. The assessment order only deals with the disallowance of claim of deduction under Section 80P - In response to the notice, issued u/s 263 Appellant had filed reply/submission on 20.02.2022, and had stated therein that the cash deposited during demonetization period. (i.e. 09.11.2016 to 13.12.2016) was collected from the customers/member and the details of the same were submitted by the Appellant in the assessment proceedings. There is no material on record to suggest that any investigation/enquiry was made by the Assessing Officer in relation to the same. No details of the inquiry/investigation conducted by the Assessing Officer have been stated in the assessment order, or the aforesaid reply/letter, or the written submissions filed before the Tribunal. The assessment order was passed without making enquiry or verification which ought to have been made by the AO in view of the fact that high value receipt of cash from third parties was one of the reasons for selection for scrutiny. The provisions of Clause (a) of Explanation 2 to Section 263 of the Act are clearly attracted in the facts of the present case. Thus, in our view, the PCIT was justified in exercising of powers of revision under Section 263 - Decided against assessee.
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