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2017 (3) TMI 96 - AT - Income TaxRevision u/s 263 - correctness of the labour expenses - Held that:- There is no dispute that CIT-A has exercised his jurisdiction vested u/s.263 in issuing the stated directions for the reason that the Assessing Officer did not conduct the relevant enquiries/verifications qua the abovestated labour expenses of the two assessee's in course of framing the respective regular assessments. We find this reason to be factually incorrect. It emerges that the Assessing Officer had issued Section 142(1) notices in both cases on 29.08.2011 seeking details of the impugned labour expenses. These two assessees filed their respective replies on 14.09.2011 in respect to the said questionnaire alongwith the copy of schedule 7 –notes to accounts forming part of the balance sheet regarding TDS on labour payments in question. The same culminated in the impugned regular assessments wherein the Assessing Officer did not make any disallowance in both the cases. We appreciate the fair stand and accept assessees’ arguments challenging correctness of CIT’s orders under challenge in these two cases thereby restoring the abovestated regular assessments in their respective cases. - Decided in favour of assessee
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