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2017 (8) TMI 323 - AT - Income TaxRevision u/s 263 - inadequate or no inquiry by AO - genuineness of sale purchase of the shares - Held that:- No justification for the learned Principal Commissioner of Income-tax to initiate proceedings under section 263 as there was no error in the assessment order as held in the case of Gopal Castings (P.) Ltd. and in the case of Narain Singla [2016 (2) TMI 1105 - ITAT CHANDIGARH] In the present case also, as demonstrated above by the learned counsel for the assessee, enquiry relating to the purchase price of the shares were made during the assessment proceedings and due reply filed by the assessee. A perusal of the reply filed by the assessee, as reproduced above, shows that he had also explained why the price of ₹ 6,554, based on the documents seized from the premises of Shri Surinder Kumar Gulati, be not substituted. Therefore, it is clear from the above that the issue had been duly enquired into during the assessment proceedings. The Assessing Officer had applied his mind on the issue and thereafter formed an opinion making no addition of the same. Further we find that the issue relating to the price of the shares of Pragati Nirman had been settled by the Income-tax Appellate Tribunal in the case of Ashish Singla (2016 (2) TMI 1105 - ITAT CHANDIGARH) wherein addition made on account of the alleged higher price fetched was deleted. Therefore the view formed by the Assessing Officer was in consonance with that of the Income-tax Appellate Tribunal. There was therefore, we hold, no justification for the learned Principal Commissioner of Income-tax to initiate proceedings under section 263 as there was no error in the assessment order. - Decided in favour of assessee.
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