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TMI Blog2022 (12) TMI 1003X X X X Extracts X X X X X X X X Extracts X X X X ..... enditure then necessary enquiry has to be done about such unexplained credits/investment. Under these given facts and circumstances of the case, we find that since the Ld. AO failed to make any such enquiry in this regard, therefore, we do not find any infirmity in the finding of the Ld. PCIT setting aside the assessment orde u/s. 143(3) to be framed afresh considering the finding given in the impugned order. Thus, all the grounds raised by the assessee are dismissed. - ITA No. 102/Pat/2017 - - - Dated:- 12-12-2022 - Shri Rajpal Yadav , Vice President And Shri Manish Borad , Accountant Member For the Appellant : None appeared For the Respondent : Shri Saumyajit Das Gupta , CIT , Ld. DR ORDER Per Manish Borad , AM ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... n the return filed for the assessment year 2012-13 on 08-09-2013. After the case being selected for scrutiny, the Ld. AO framed the assessment u/s. 143(3) of the Act rejecting the books of account u/s. 145(3) of the Act and estimating the profits thereby assessing income at Rs. 72,31,910/-. 6. Subsequently, the Ld. PCIT called for assessment records invoking the jurisdiction u/s. 263 of the Act and show cause notice dt. 22-02-2017 issued raising the following two issues:- 1) It has been observed that in the assessment the assessing officer had not properly examined the issue of Rs. 1,61,03,705/- credited in your bank account of SBI, Gopalganj and that a sum of Rs. 5,81,189/- was left to be included in the gross contractual receipt du ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... nd on the issues raised/referred in the show cause notice, thus, set aside the assessment order dt. 19-03-2015 and directed the Ld. AO to frame the assessment afresh after considering the observations made in the impugned order. 9. Aggrieved, the assessee is now in appeal before this Tribunal. 10. The Ld. Departmental Representative (in short, the Ld. DR) vehemently argued supporting the impugned order of the Ld. PCIT. 11. We have heard the Ld. DR and perused the material placed on record before us. The Ld. PCIT issued show cause notice u/s. 263 regarding the issues firstly, a sum of Rs. 1,61,03,705/- credited in the bank account of SBI, Gopalganj, that a sum of Rs. 5,81,189/- was left to be included in the gross contractual receip ..... X X X X Extracts X X X X X X X X Extracts X X X X
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