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2022 (11) TMI 1109 - AT - Income TaxRevision u/s 263 by CIT - Addition u/s 68 - HELD THAT:- We find that the transactions referred to by the CIT in the impugned order has never been examined by the assessing officer. No enquiry has been conducted relating to the alleged sum. It is also surprising to note that even when the tax audit report was available with the assessing officer and it was specifically mentioned that loans or advances have been taken by the assessee from M/s. DGIAPL, AO failed to take any action. It could have been a situation that the assessing officer after examining the transactions, ledger account and other relevant details have come to a conclusion that they are not in the nature of loans or advances. But this action of carrying out necessary exercise is completely missing at the end of the assessing officer and in the given scenario where only few cases are selected for scrutiny such type of scrutiny proceedings as has been carried out by the assessing officer are erroneous so far as they are prejudicial to the interest of the revenue wherein the important aspects and the crucial financial transactions having sufficient volume in terms of value remained to be examined by the AO. We fail to find any infirmity in the finding of the CIT holding the assessment order as erroneous and prejudicial to the interest of the revenue. Thus, the finding of the CIT in the order passed u/s 263 of the Act, is confirmed and grounds of appeal raised by the assessee are dismissed.
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