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TMI Blog2022 (7) TMI 1211X X X X Extracts X X X X X X X X Extracts X X X X ..... of Rs.3,80,000/- only and there is no bar under the law that the working partner should be full time working partner. Therefore, she is working as a part time / temporary teacher in the said school. Considering all, there is also possibility to attend the work during holidays and after school hours. Therefore, we are of the view that initiation of proceedings u/s 263 is not valid on this count. Hence, we set aside the order passed by the Ld.Pr.CIT u/s 263 and allow the grounds raised by the assessee. - I.T.A. No. 253/Viz/2021 - - - Dated:- 22-7-2022 - SHRI DUVVURU RL REDDY, HON BLE JUDICIAL MEMBER And SHRI S BALAKRISHNAN, HON BLE ACCOUNTANT MEMBER Appellant by : Shri C.Subrahmanyam, AR Respondent by : Shri M.N.Murthy Naik, ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... s regard during the assessment proceedings. Therefore, revisional proceedings were initiated u/s 263 by issuing show cause notice on 20.08.2019 and the same was served on the assessee. On this aspect, contention of the assessee was that Smt. Dadi Anuradha monitors administration works at the office, such as, verifying the loan processing documents and interacting with the customers and general administration partly in a day. The Ld.Pr.CIT was not satisfied with the explanation offered by the assessee and passed an order u/s 263 with a direction to gather necessary evidences, cause proper verification and pass consequential order after giving opportunity of being heard to the assessee. 3. Aggrieved by the order of the Ld.Pr.CIT, the asses ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ing documents and interacted with parties etc and meagre amount of Rs.3,80,000/- was fixed as remuneration to the working partner. Therefore, there is no prejudice to the interest of the revenue as contemplated by the Ld.Pr.CIT. Hence, the Tribunal may be pleased to set aside the order passed u/s 263. 5. Per contra, the Ld.Counsel for the revenue submitted that there is no verification made by the AO, therefore, proceedings u/s 263 were initiated. 6. We have heard both the parties and perused the material placed on record. The main contention of the assessee is that Smt.Dadi Anuradha is a teacher. After school working hours, she used to attend office for an administration work and verification of loan applications etc and is paid reas ..... X X X X Extracts X X X X X X X X Extracts X X X X
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