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2022 (7) TMI 538 - AT - Income TaxRevision u/s 263 - case of the Assessee was selected for scrutiny on the reason "large cash deposit in saving bank account(s), whether cash deposits have been made from disclosed sources" - Assessee before us contended that detailed and proper enquiry was done by the AO in this case and therefore the impugned order is liable to be set aside - HELD THAT:- We have given thoughtful considerations to the contention of the Assessee and realize that the AO has failed to verify the basic foundation i.e. Licence for doing the business of money lending by the Assessee, on the basis of which the Assessee claimed to have deposited the amount under consideration. Hence the contention of the Assessee is untenable. All the facts enumerated goes to show that foundation of enquiry qua claim of the Assessee is missing and the AO made the assessment order in cursory manner by conducting farce enquiry, which infact can not be termed as enquiry, hence we are of the considered view that in the instant case no enquiry qua issue involved, was done by the AO and therefore the Ld. PCIT was fully justified to reopen the case of the Assessee u/s. 263 of the ACT by holding the assessment order for A.Y. 2016-17 as erroneous and bad in law in so far as prejudicial to the interest of Revenue. Considering the conclusion drawn by Ld. PCIT and peculiar facts and circumstances of the case narrated above, we do not find any substantive reason and justification to interfere in the impugned order as the same do not suffer from any perversity or impropriety or illegality, consequently no interference is warranted. Appeal filed by the Assessee is dismissed.
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