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2022 (5) TMI 1093 - AT - Income TaxRevision u/s 263 by CIT - Case selected for scrutiny through CASS - assessee has made fresh investment in unlisted equity shares of two companies and observed that though the source of fund is out of business receipt, but the officer has not conducted any verification/enquiry to verify the veracity of the claim - HELD THAT:- Assessee was selected for limited scrutiny for two issues namely “sales turnover mismatch” and “investment in unlisted equity shares”. In the body of the assessment order there is no discussion about the reasons for selection for limited scrutiny nor there is any discussion of the issues raised before us. Though there is a reply filed by the assessee before the ld. PCIT stating that the required information were filed but they are not sufficient to prove that whether ld. AO raised sufficient enquiry about the investment in unlisted equity shares. In the case of limited scrutiny assessment, AO is duty bound to examine the details minutely which are linked to the reasons for limited scrutiny. Records do not contain the copy of notice issued u/s 142(1) of the Act, replies filed by the assessee, specific questions raised by the ld. AO referring to the investment in unlisted equity shares and the source of such investment. In the impugned order, ld. PCIT has restored the issue to the file of the ld. AO for examining the above referred issue of investment in unlisted equity shares by invoking the powers u/s 263 and restoring the file back to the ld. AO for examining the same in light of the documentary evidences to be filed by the assessee. We, therefore, under the given facts and circumstances of the case are of the considered view that the ld. PCIT has rightly assumed jurisdiction u/s 263 of the Act and restored the issue of examination of investment in unlisted equity shares of two companies to the file of ld. AO. Accordingly, all the grounds raised by the assessee are dismissed.
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