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TMI Blog2023 (10) TMI 128X X X X Extracts X X X X X X X X Extracts X X X X ..... sed the impugned assessment order. (2) That the assessment order U/S 143(3) dated 19-12-2018 as passed by the Ld Assessing Officer is neither erroneous nor prejudicial to the interests of the revenue. (3) Observations made, inferences drawn and findings recorded by the Worthy Principal Commissioner of Income Tax in her order passed U/S 263 are incorrect, unreasonable and are untenable in law. 3. The ld. counsel of assessee submitted that The Ld Assessing Officer has duly applied his mind to the issue raised in the notice U/S 263 and after having been satisfied on the same, took a possible view based on the facts of the case and thereby passed the impugned assessment order. He further contended that the assessment order U/S 143(3) da ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... quiry in accepting the explanation of assessee regarding source of cash deposit in the assessment order para 3, which cannot be alleged as erroneous and prejudicial interest of revenue. 5. The assessee has placed reliance on various judgements to submit that the ld. PCIT was not correct in re-agitating the issue which was dealt and adjudicating by the Assessing Officer in detail by issuing notices along with questionnaire to the assessee and which were properly replied by the assessee and after taking on record reply and documentary evidences the Assessing Officer by way of detail discussion in para 3 of order allowed and accepted the claim of assessee towards source of cash deposit to his bank account. Therefore the ld. PCIT was not valid ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... trust is opened the fees received will be deposited in the said personal saving account of assessee. The copy of trust deed dated 28.07.2015 revealed that the assessee was settler of trust and was having position of president therein. 8. In view of findings recorded by the Assessing Officer in para 3 of assessment order and foregoing factual matrix about the required enquiry conducted by the Assessing Officer in the limited scrutiny proceedings on the sole issue of source of cash deposit to the bank account of assessee, we are of the view that the Assessing Officer has made all necessary efforts and inquiry about the source of cash deposit to the bank account of assessee and thereafter accepted the claim of assessee explaining the source o ..... X X X X Extracts X X X X X X X X Extracts X X X X
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