TMI Blog2022 (4) TMI 1265X X X X Extracts X X X X X X X X Extracts X X X X ..... issions and relied on the decisions of various Benches of the Hon'ble Tribunal and Hon'ble High Courts as detailed in written submissions. We have gone through the records and written submissions of the assessee. We find that there is no specific mentioning about the submissions made by the assessee in the order of the AO. In view of the above invoking the powers under section 263 of th ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... y, the case was selected for scrutiny under CASS and statutory notices U/s. 143(2) and 142(1) were served on the assessee. In response to the notices the assessee's representative appeared and filed the details required by the Ld. AO. The Ld. AO after examination of the books of accounts and other details called for, completed the assessment by adding ₹ 1,14,000/- as interest income from ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... s High Courts found that the assessment order passed U/s. 143(3) prima facie erroneous and prejudicial to the interest of the Revenue and therefore proposed to revise the same U/s. 263 of the Act. The Ld. Pr. CIT after carefully considering the submissions made by the assessee with respect to loan creditors set-aside the file to the Ld. AO for the limited purpose of verification of the creditworth ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... f various Benches of the Hon'ble Tribunal and Hon'ble High Courts as detailed in written submissions. 6. We have gone through the records and written submissions of the assessee. We find that there is no specific mentioning about the submissions made by the assessee in the order of the Assessing Officer. In view of the above invoking the powers under section 263 of the Act by the Ld. Pr ..... X X X X Extracts X X X X X X X X Extracts X X X X
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