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2024 (2) TMI 460

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..... 0A(7) (Gratuity Provision) - HELD THAT:- As in this case, the AO has examined the case of the assessee for which it was selected under Limited Scrutiny . Under the above facts and circumstances, we are of the considered opinion that it is not a fit case to invoke the provisions of section 263 and pass revision order, where the case of the assessee was picked up for limited scrutiny in view of the decision of Smt. Padmavathi [ 2020 (10) TMI 425 - MADRAS HIGH COURT] as the ld. PCIT cannot enlarge the scope of limited scrutiny. Thus, the revision order under section 263 of the Act stands quashed. Appeal filed by the assessee is allowed. - Shri V. Durga Rao, Judicial Member And Shri Manjunatha, G., Accountant Member For the Appellant .....

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..... l provisions of the Act. Thus, by invoking the provisions of section 263 of the Act, the ld. PCIT issued notice to the assessee proposing for revision under section 263 of the Act. The assessee filed its written submission before the ld. PCIT. After considering the submissions of the assessee, wherein, the assessee has stated that they have inadvertently stated the amount of ₹.24,48,406/- under provision for bad debts while reporting their income. Thus, the ld. PCIT was of the opinion that the assessment order passed under section 143(3) r.w.s. 143(3A) 143(3B) of the Act is erroneous and prejudicial to the interest of Revenue and accordingly set aside the assessment order and directed the Assessing Officer to re-examine and pass fre .....

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..... Officer issued notice under section 142(1) of the Act to the assessee calling for various details. The assessee filed its reply on 11.03.2020. The Assessing Officer, vide his notice under section 142(1) of the Act dated 30.07.2020, called for various details as per annexure to the notice and the same are reproduced as under: ANNEXURE With respect to your reply filed on 11/03/2020 in response to notice issued to you u/s 142(1), you are requested to kindly furnish the below specified details: 1. In your ITR filed for the A.Y.2017-18, there was loan shown in column loan from others at Rs. 5,27,92,257/- whereas in your submission, loan outstanding as on 01.04.2017 is Rs. 11,12,81,165/-. Please reconcile the same with a break-up .....

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..... ou need fifteen (15) days time to upload the same . In this regard, you are requested to please furnish the same in respect of an Unsecured Loans (only) taken by you during the year. 7. After considering the reply filed by the assessee and after verification of the details furnished by the assessee, the Assessing Officer has completed under the assessment under section 143(3) r.w.s. 143(3A) 143(3B) of the Act. The case of the assessee is that under limited scrutiny, the assessee has furnished all the details called for before the Assessing Officer and it was merely a clerical mistake and inadvertently stated the amount of ₹.24,48,406/- under provisions for bad debts while reporting the income. During the revision proceedings, t .....

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