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2023 (11) TMI 976 - ITAT CHENNAIRevision u/s 263 - return filed by the assessee was selected for limited scrutiny through CASS - difference in closing stock compared to the return of income of the previous year and cash deposits reported in SFT-14 - HELD THAT:- As on perusal of the assessment order, we find that during the course of assessment proceedings, AO has questioned about the correct valuation of stock alone. In the assessment order, AO has not made any mention towards enquiry about the cash deposit as reported in SFT 14. Thus, we are of the opinion that the assessment order is very cryptic without speaking about the verifications made by the AO for which the return filed by the assessee was selected for “Scrutiny”. Against the notice u/s 263 of the Act, before the ld. PCIT, the assessee has explained that the assessee was engaged in real estate business and sold plots during the year for a total consideration and the same has not been reflected in the bank account of the assessee for the reason that the sale proceeds of the plots are cash sales only. On an overall examination of the records, PCIT has correctly observed that no proper examination/verification was done by the AO while passing the assessment order u/s 143(3) on the above issue and the AO had passed the order without application of mind. We find no reason to interfere with the order passed by the PCIT and accordingly, the appeal filed by the assessee is dismissed.
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