TMI Blog2022 (6) TMI 948X X X X Extracts X X X X X X X X Extracts X X X X ..... ansaction with M/s. Santosh Agency remained unexamined. We notice that all the above observations made by ld. PCIT in the impugned order were alleged not to have been verified by the ld. AO. The submissions made by the assessee before ld. PCIT appearing in the impugned order are not sufficient to explain the said transactions. No detailed discussion is made in the assessment order also. No paper book has been filed by the assessee to demonstrate that whether ld. AO raised necessary queries/conducted enquiry on the issues referred herein above and whether the assessee had furnished a detailed reply including relevant documents to satisfy the AO. We find no reason to interfere in the finding of ld. PCIT holding the assessment order date ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... d company engaged in the business of investment in shares and securities. NIL income was declared on 23.03.2013. Assessment order framed u/s 147/143(3) of the Act dated 07.12.2018. Return of income was accepted. Subsequently, ld. PCIT on going through the assessment records, was prima facie of the view that there was a complete lack of enquiry by the ld. AO while framing assessment on 07.12.2018 on the following issues: 2. On perusal of the assessment record of the assessee, it was observed that an information was received from the ITO (lnv.), Unit-3, Kolkata that an amount to the tune of Rs. 11,00,000/- was transferred to the assessee's A/c from M/s. Patra Bastralaya. However, from the cash trail attached thereto, it revealed that ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ent and adequate enquiry on the aforesaid issues. 4. Before ld. PCIT written submissions were filed on 24.02.2021 by the assessee which were considered but not found acceptable by the revisionary authority and directed the ld. AO to pass afresh assessment order considering the issues raised in para 2 of the impugned order. 5. Aggrieved, the assessee is in appeal before this Tribunal raising the following grounds: 1. For that the Ld. Principal Commissioner of Income Tax, Kolkata -2 has erred in law as well as on facts of the case by passing order u/s. 263 of the I.T. Act, 1961 on 26/02/2021. 2. For that the Ld. Principal Commissioner of Income Tax, Kolkata-2 has erred in law as well as on facts of the case by not paying hee ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e that ld. PCIT referred to two transactions, firstly, transfer of Rs. 11,00,000/- to the assessee s account from M/s. Patra Bastraiaya. Another transaction was of Rs. 27,00,000/- reflecting in the assessee s bank account received from M/s. Santosh Agency on 14.06.2010. Source and nature of transaction of Rs. 27,00,000/- with M/s. Santosh Agency remained unverified. No verification was done to this effect in the course of assessment. Also the connection between the transaction of Rs. 11,00,000/- with M/s. Patra Bastraiaya and the transaction with M/s. Santosh Agency remained unexamined. 9. We notice that all the above observations made by ld. PCIT in the impugned order were alleged not to have been verified by the ld. AO. The submissions ..... X X X X Extracts X X X X X X X X Extracts X X X X
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