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2023 (10) TMI 846 - AT - Income TaxRevision u/s 263 - Addition u/s 68 - As per CIT AO passed a cryptic order accepting the returned income as nil as per declaration of assessee - as alleged no enquiries whatsoever had been found to have been made in respect of the identity, creditworthiness and genuineness of the loans and advances - HELD THAT:- AO has passed a very brief and cryptic order. However, in the body of the order he has mentioned that specific query were raised regarding two issues viz. (i) large increase of unsecured loan during the year and low income in compression to high amounts of loan, advances and investment in shares and noted that in response to notices AR of assessee attending proceedings and after taking on record necessary details, explanation and evidences returned income at Nil was accepted. We are unable to see any endeavour exercise by the AO regarding verification, examination and adjudication of both the issues were picked up for scrutiny assessment proceedings even from the statement of facts we are unable to see details of any notice either u/s. 142(1) or any other provisions of the Act except notices dated 19.09.2017 u/s. 133(6) of the Act to sister concerns (2) of assessee. Even despite service of notice the assessee is not representing and perusing his case before this Tribunal. AO accepted returned income of assessee without any verification and examination of both the issues therefore it is a clear case of inadequate and insufficient enquiry. PCIT was quite justified and correct in alleging the assessment order as erroneous and prejudicial to the interest of revenue by following the preposition rendered in the case of Shri Amitabh Bachhan [2016 (5) TMI 493 - SUPREME COURT]. Decided against assessee.
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