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2023 (11) TMI 1046 - AT - Income TaxRevision u/s 263 enlarging scope of limited scrutiny - assessee case was selected for scrutiny assessment under limited scrutiny category - as per CIT assessee has paid rent of shop and godown but not deducted TDS u/s. 194I, assessee has claimed payment of interest in the profit & loss account and deducted TDS u/s. 194A of the Act and hence, due to short deduction or no deduction of TDS, 30% of these expenses need to be disallowed by invoking the provisions of section 40(a)(ia) and there is delayed remittance of employees contribution of EPF - assessee’s case was selected for limited scrutiny under CASS for High value cash withdrawals during the year reported and Large value cash deposit during demonetization period. HELD THAT:- Assessee’s case was selected for scrutiny for verification of high value cash withdrawals and large value of cash deposits made during demonetization period. Apart from this, the AO was not authorized to look into any other issue. Even though on merits, the assessee has a case on each of the proposed disallowance by PCIT in his revision order passed u/s. 263 of the Act. Thus PCIT want to enlarge the scope of limited scrutiny for which power is not available with the PCIT u/s. 263 of the Act, for the reasons stated in Co-ordinate Bench decision in the case of Duckwoo Autoind Pvt [2023 (1) TMI 361 - ITAT CHENNAI] Appeal filed by the assessee is allowed.
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