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2023 (2) TMI 577 - AT - Income TaxRevision u/s 263 - deposit of cash and utilization of cash towards purchase of immovable property was never examined in the scrutiny assessment - HELD THAT:- Wealth tax returns were not filed by assessee for the relevant assessment years 2014-15 and 2015-16 despite the fact that the AO issued reopening notice u/s.16 of the Wealth Tax Act. Further, the assessments were completed only on 11.03.2022 just before issuance of notice dated 24.03.2021 which is again after completion of assessment by the AO which is dated 10.12.2019 and even after issuance of showcause notice by the PCIT which is dated 22.02.2022. It means that the wealth tax assessments h ave no value to consider the explanation of the assessee. AO has neither examined the source of cash deposit and cash payment towards purchase of immovable property and in the absence of any enquiry conducted by the AO in this regard, the assessment order is rightly been held to be erroneous and prejudicial to the interest of Revenue. No infirmity in the order of PCIT revising the assessment - Decided against assessee.
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