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2022 (10) TMI 150 - AT - Income TaxRevision u/s 263 by CIT - Case of the assessee was selected for limited scrutiny for the purpose of verification of cash deposits during the year - HELD THAT:- As noticed that the assessee has submitted the details as called for by the AO from time to time. However, in the assessment order, the AO has not brought out any details of verification of cash deposits carried out by him during the course of assessment and he has passed a non-speaking order accepting the explanation given by the assessee. The source of cash deposits from “safe custody account” was not questioned by the AO by calling for ledger accounts etc., nor has the assessee submitted any details in this regard during the assessment proceedings. In the present case, limited scrutiny was to be done for verification of cash deposits and the source of cash deposits from the safe custody account is not examined by the AO by calling for relevant details from the assessee. The AO ought to have examined the same to go into the root of these deposits whereas in the instant case, the AO has not questioned the information supplied by the assessee with regard to the source of cash deposits into the safe custody account and has simply accepted those details without further enquiry. In such circumstances, it cannot be said that the AO has made any enquiry or taken a particular view by application of mind on the issue. As relying on the ratio laid down by the Hon’ble Delhi High Court in the case of Gee Vee Enterprises [1974 (10) TMI 29 - DELHI HIGH COURT], we hold that there is no infirmity in the impugned order passed by the PCIT u/s. 263 of the Act. Appeal by the assessee is dismissed.
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