2023 (11) TMI 446

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..... Act of Ld. PCIT contrary to Explanation 2 of Section 263 of the Act?" (ii) "Whether the Hon'ble Tribunal was justified in allowing the appeal of the assessee against the order u/s. 263 of the Income Tax Act?" (iii) "Whether the Hon'ble Tribunal was justified in allowing the appeal of the assessee against the order u/s. 263 of the Income Tax Act of Ld. PCIT when there was gross inadequacy in inquiry conducted as per order of the Hon'ble Supreme Court in case of Principal Commissioner of Income-tax, Surat-2 v. Shreeji Prints (P.) Ltd. [2021] 130 taxmann.com 294 (SC) and also in the case of The Commissioner of Income Tax Vs. M/s. Paville Projects Put. Ltd. (CA No. 6126 of 2021 (SC)?" 3. This Appeal has been filed under Section 260-A o .....

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..... in the facts before us, in the case of the assessee, the AO during the course of assessment proceedings, made enquiries on this issue and after consideration of written submissions filed by the assessee and documents / evidence placed on record, and then framed the assessment under section 143(3)/147 of the Act accepting the return of income. This fact can be verified from the notices issued under section 142(1)/148 of the Act by the AO and reply submitted by the assessee against such notice. i. Notice u/s 148 of the Act dated 05- 09-2018: On verification of information received, it is found that cash deposit amounting to Rs,21,57,400/- was deposited by the assessee in his savings bank account with Kotak Mahindra Bank wherein the asse .....

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..... i. Reply dated 18-09-2018 Source of Cash Deposit during the year FY 2010-11 During the FY 10-11 my son Saral Kothari has deposited Rs.21,57,400/- in Kotak Mahindra Bank Saving bank account no.08310110006741 wherein I am the join Holder. Details of cash withdrawal made from Kotak Mahindra Bank my son Saral Kothari are as under: (PAN of Saral Kothari: ALZPK2887M) Copy of Bank statement and cash book of my son Saral Kothari are already submitted vide my earlier submission. Month Cash Withdrawal from Kotak Mahindra Bank April 7,500 May 3,16,800 June 1,54,500 July 60,800 August 21,000 September 2,93,300 October 1,70,960 November 4,53,500 December 89,800 January 46,600 February 54,200 March 5 .....

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