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2018 (1) TMI 1286 - AT - Income TaxValidity of order u/s 263 - addition towards undisclosed sales - Held that:- We find that assessee has supplied detailed information to the assessing authority relating to issue of stock difference given to bank vis-à-vis books of account. After considering this detailed reply of the assessee dated 26/11/2009 the AO has framed the assessment order on 16/12/2009 and completed the assessment proceedings after making addition towards undisclosed sales. Therefore, are satisfied to the extent that against the specific query raised by the Assessing Officer relating to stock statement given to bank and after going through this reply, assessment has been completed taking one of the possible views thereby accepting that assessee had a bonafide reason for such difference of value of stock within the range of 10%. It has been consistently held in various judgments that it is not mandatory for the Assessing Authority to mention each and every information recorded or details received during the course of assessment proceedings in the body of assessment order. This even applies in the instant appeal also where even though details were specifically filed replying to the Assessing Officer’s query, it did not find any mention in the body of the order because of the satisfaction of the Assessing Authority on the issue. The assessment order passed u/s 143(3) of the Act dated 16/12/2009 is neither erroneous nor prejudicial to the interest of Revenue and therefore, CIT erred in passing order u/s 263 - Decided in favour of assessee.
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