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TMI Blog2022 (4) TMI 538X X X X Extracts X X X X X X X X Extracts X X X X ..... erial justifying his exercise of revision jurisdiction u/s 263 relating to the aforesaid two issues. The only issue raised by the ld. PCIT in para 6 of the impugned order is relating to non-deduction of TDS by the assessee on carriage inward loading and unloading expenses, however, while setting aside the assessment order, PCIT has not directed to the AO to examine the aforesaid issue of non-deduc ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ppeal of assessee allowed. - I.T.A. No. 119/Kol/2021 - - - Dated:- 28-3-2022 - Shri Sanjay Garg , Judicial Member And Shri Girish Agrawal , Accountant Member None appeared on behalf of the appellant Shri Amol Kamot, CIT-DR, appeared on behalf of the respondent ORDER Per Sanjay Garg , Judicial Member : The present appeal has been preferred by the assessee against the or ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... and after hearing the ld. DR. 3. A perusal of the impugned order of the ld. PCIT passed u/s 263 of the Act reveals that the same is a vague order and there is no clarity as to what error has been pointed out by the ld. PCIT in the assessment order in relation to the aforesaid two issues for which the matter has been remanded back to the A.O. A perusal of the relevant paras of the impugned orde ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ing to the aforesaid issues. In our view, the ld. PCIT must have some basis to form the opinion that the order of the Assessing Officer was erroneous and prejudicial to the interest of the Revenue and that basis should have been pointed out in the impugned order by the ld. PCIT. The assessment records were available to the ld. PCIT but he failed to point out any defect or discrepancy in the accoun ..... X X X X Extracts X X X X X X X X Extracts X X X X
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