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2022 (8) TMI 804 - HC - Income TaxRevision u/s 263 - violation of the provisions of Section 13(1) (c) - monies for purchase of the land was sourced from the said society, however, the aspect of violation of Section 14(1) (c) was not raised by the AO, while completing the assessment of the aforesaid society - HELD THAT:- We are of the view that no substantial question of law arises for our consideration in the present appeal. The order passed by the PCIT under Section 263 as well as the order passed by the Tribunal are completely justified in the facts of the case. In fact, we are shocked to see the manner in which the AO dealt with the case after issuance of notices under Section 143(2) & 142(1) of the Income Tax Act along with questionnaire to the assessee. The least that the AO was called upon to do was to require the assessee to make good his claim that the amount was sourced from Kulwant Kaur Kukreja Educational Society. The violation of Section 13(1) (c) of the Income Tax Act also required examination after examination of the first aspect as aforesaid. We also fail to appreciate / understand as to what is the reason for the assessee to avoid the inquiry and scrutiny with regard to the source of funds through which the land was purchased by the assessee. We, therefore, dismiss this appeal and we also direct the Principal Commissioner of Income Tax, Dehradun to administratively examine whether any action is called for against the AO in the light of the manner in which he has conducted himself while dealing with the proceedings after issuance of the notices under Section 143(2) and Section 142(1) of the Income Tax Act.
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