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2023 (10) TMI 691 - ITAT CHANDIGARHRevision u/s 263 by CIT - additional professional income surrendered by the assessee - As per CIT AO had failed to make necessary enquiries and take note of the aforesaid statements of the assessee made during the survey action - HELD THAT:- We find that the statement of the assessee as well as the said surrender letter of the assessee, are of the same date i.e. 26.09.2016, therefore, it cannot be said that the said letter issued by the assessee is an after-thought. Rather, if we read both the statement as well as letter together, the sum and substance of the entire conversation would be that the assessee had offered the said amount of Rs. 70 lacs as his additional professional income. There is no case of the Department that the assessee has any other source of income. AO during the assessment proceedings, had made adequate enquiries in this respect and accepted the explanation offered by the assessee. We, therefore, do not find any justification on the part of PCIT in holding the assessment order as erroneous and prejudicial to the interests of the Revenue. The exercise of revisionary jurisdiction u/s 263 of the Act, in this case is held to be not justified and therefore, the revision order passed u/s 263 of the Act is hereby quashed. Appeal of the assessee stands allowed.
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