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2022 (9) TMI 186 - ITAT KOLKATARevision u/s 263 - Addition u/s 68 - assessee failed to make any compliance to the show cause notice issued u/s 263 of the Act and even after being provided sufficient opportunities on multiple occasions, the assessee failed to reply or furnish any submission - HELD THAT:- In the first round of assessment proceedings No additions were made. In the second round of assessment proceedings carried out in direction to the order u/s 263 AO has stated to have examined the financial statements of the assessee and other documents relating the investments made in the company. However, no such details are placed on record. There is no information before us as to what was the amount of share application money, credit entries, details of identity of the share applicants, documents supporting the genuineness and creditworthiness of such transactions. The finding of AO in the assessment order is in a summary manner which is not indicating the details in a correct manner. Also, the order u/s 263 is not placed before us which would have helped us to know about the directions given by ld. Pr. CIT and whether such directions have been complied by the ld. AO. Where the assessee has opted not to appear before the ld. Pr. CIT nor before this Tribunal and has merely filed the appeal but has not pursued the appeal so filed by it and in the given situation where we are unable to lay our hands on any of the details of the financial transactions carried out by the assessee during the year and whether such transactions have been examined by ld. AO in the manner directed by ld. Pr. CIT passed u/s 263 we fail to find any infirmity in the finding of the ld. Pr. CIT in the impugned order - We, accordingly confirm the said finding setting aside the assessment order passed u/s 143(3) which is, thus, rightly held to be erroneous and prejudicial to the interests of the Revenue. Accordingly, all the grounds raised by the assessee in the instant appeal are dismissed.
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