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2021 (9) TMI 1211 - ITAT BANGALORERevision u/s 263 by CIT - AO did not make any reference to the facts that transpired in the course of assessment proceedings and make a reference to those facts in the assessment order - HELD THAT:- AO accepting the return of income does not make any reference to any of the arguments put forward on behalf of the assessee and has merely accepted the return of income filed by the assessee -The entire details were filed and the order itself indicates that it can be inferred that the Assessing Officer not only made enquiries, but satisfied himself with the assessee's replies furnished from time to time in support of its stand. As decided in Infosys Technologies Ltd [2012 (1) TMI 76 - KARNATAKA HIGH COURT] if the order of the AO does not disclose the basis of his conclusion, then jurisdiction u/s. 263 of the Act can be ignored. In the present case, the order of the AO is silent on his conclusions on issues raised by him in the notice u/s. 143(2) of the Act and merely accepted the returned income. Therefore, the CIT was justified in directing the AO to examine the issues that were set out for limited scrutiny under CASS afresh. The assessee is always at liberty to show as to how no adverse inference or addition is called for. We, therefore, confirm the order of the CIT. - Decided against assessee.
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