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2023 (1) TMI 1007 - AT - Income TaxRevision u/s 263 by CIT - cash deposits in saving bank account - as per CIT A.O. also has not made any enquiry as to how such huge amount of Rs. 12,00,000/- is deposited in the bank account of the assessee - HELD THAT:- It is seen from the assessment order passed by the Assessing Officer is without any details and no information about the claim of agricultural land. When the sale of two lands amounting to Rs. 31,55,000/- and Rs. 30,27,000/- respectively. The Assessing Officer has not raised any question about agricultural income derived from the above lands by the assessee. The assessing officer has also not verified the nature of cultivation from the above lands in the previous assessment years, population of the village and distance from the nearest Municipality. Thus in our considered opinion, the Assessing Officer has not made necessary enquiries before allowing the claim u/s. 2(14) of the Act. Similarly the cash deposits in Bank accounts is not verified by the A.O. with proper enquiry. PCIT has rightly invoked the provision of Section 263, wherein the assessment order passed by the Assessing Officer is on account of inadequate enquiry and non-application of mind to the facts of the case presented by the assessee. Therefore the Ld. PCIT set aside the erroneous assessment order passed by the Assessing Officer, with a direction to examine the issues afresh and determine the appropriate tax liability by giving adequate opportunity to the assessee. We do not find any infirmity in the order passed by the Ld. PCIT. - Decided against assessee.
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