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TMI Blog2023 (2) TMI 252X X X X Extracts X X X X X X X X Extracts X X X X ..... the appeal preferred by the assessee against the order of the Ld. Principal Commissioner of Income Tax-Asansol (hereinafter referred to as the Ld. PCIT"] passed u/s 263 of the Income Tax Act, 1961 (hereinafter referred to as the Act) dated 26.03.2022 for the AY 2016-17. 2. The assessee has challenged the revisionary jurisdiction exercised by the Ld. PCIT u/s 263 on the ground of being invalid and ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... which was replied by the assessee vide written submission dated 09.03.2022. The Ld. PCIT after considering the reply of the assessee rejected the same and revised the assessment vide order dated 29.12.2019 directing the AO to frame the assessment afresh. 4. We have heard the rival submissions and perused the material on record. The Ld. A.R argued that there was no mistake in the claim of MAT as ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... not find any mistake in the claim of brought forward MAT by the assesse and accordingly the assessment order framed is neither erroneous nor prejudicial to the interest of the revenue. On the issue no. 2 ,the provisions made for doubtful debts amounting to Rs. 6,05,42,000/- on which the Ld. PCIT revised the assessment , we observe that there is no mistake in the computation of disallowance. We not ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... f which is placed at page 39 of the PB. Accordingly on the second issue on which the ld CIT(A) revised the assessment order, there is no mistake in the assessment order. In other words the assessment order is neither erroneous nor prejudicial to the interest of the revenue. It is settled legal position that in order to invoke the revisionary jurisdiction u/s 263 of the Act , the satisfaction of tw ..... X X X X Extracts X X X X X X X X Extracts X X X X
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