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2023 (7) TMI 371 - ITAT DEHRADUNRevision u/s 263 - disallowance of purchases - AO had disallowed only a partial sum - Assessee applied for VSV scheme - HELD THAT:- Once the conclusion is reached that M/s Meet Enterprises was engaged in providing accommodation entries in the form of providing bogus sale bills, the ld. AO ought to have disallowed the entire purchases made by the assessee from the said party. Strangely the ld. AO had disallowed only a partial sum representing payments made to M/s Meet Enterprises during the year. The ld. AO had ignored the fact that though the payment was made only for Rs 73,45,040/-, the assessee herein had claimed deduction for purchases to the tune of Rs 1,06,80,540/-. This is a grave error committed by the ld. AO in his assessment. Though the assessee had sought to settle the dispute arising out of reassessment order under VSV scheme, it would be limited only to the extent of disallowance / addition made in the said reassessment . The assessee is not given any blanket immunity so as to prevent the revenue from looking into other matters relating to such assessment year. We hold that the ld. PCIT was duly justified in invoking his revisionary jurisdiction u/s 263 of the Act by cancelling the reassessment framed by the ld. AO as erroneous and prejudicial to the interest of the revenue. Accordingly, the grounds raised by the assessee are dismissed.
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