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TMI Blog2019 (11) TMI 1712X X X X Extracts X X X X X X X X Extracts X X X X ..... nt proceedings did not verify claim of assessee under Rule-7A(2). There is nothing on record to establish that even a query was raised by AO in regards to the claim. From the statement furnished by the assessee, we note that the amount represent opening balance and the same has been capitalized by the assessee. During the year under consideration assessee has incurred expenses of 8,80,48,770/- out ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 263 of the Act for assessment year 2014-15 on following grounds of appeal: 1. The order of the Pr..CIT is contrary to law, facts, evidences on record and is not maintainable in law. 2. The ld .Pr. CIT erred in not considering the evidences filed before her on merits which evidences clearly shows that there is no loss of revenue and hence no prejudice to the interest of the revenue which rende ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... essment was completed under section 143(3) of the Act vide order dated 26/12/16 wherein, addition of ₹ 7,25,42,337/- was made. 2.1 Subsequently, vide notice dated 24/09/18 Ld. CIT held order dated 26/12/16 to be erroneous and prejudicial to the interest of revenue to the extent of allowance claimed by assessee on rubber tree plantation under Rule 7A(2) amounting to ₹ 7,91,38,318/-. L ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... in (2000) 243 ITR 83 as well as Hon'ble Supreme Court in case of CIT vs Amitabh Bachchan reported in 384 ITR 200. She submitted that reason for revision of assessment order was proposed due to no enquiry by Ld.AO and therefore deserves to be upheld. 4. We have perused submissions advanced by both sides in the light of records placed before us. 4.1 Admittedly, Ld.AO at the time of original assess ..... X X X X Extracts X X X X X X X X Extracts X X X X
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