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TMI Blog2023 (5) TMI 879X X X X Extracts X X X X X X X X Extracts X X X X ..... e assessee by placing any contrary evidence, therefore, in the absence of material rebutting the finding of the Pr. CIT, no reason to interfere in the finding of CIT. Order pass u/s 263 stands accordingly affirmed. Decided against assessee. - ITA No. 3789/DEL/2018 - - - Dated:- 19-5-2023 - Shri Kul Bharat, Judicial Member And Shri Pradip Kumar Kedia, Accountant Member For the Assessee : N ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... .CIT is bad in law being cryptic, self contradictory, unreasonable and totally based on conjectures, surmises and wrong facts. 4. The order under section 263 made by the Ld Pr.CIT is bad in Law having not fully considered the submissions of the appellants. 5. The order under section 263 has been made by the Ld. Pr.CIT without proper opportunity of being heard being afforded to the appe ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ceedings of A.Y. 2014-15 the creditors were established as bogus out of amount of Rs. 6,89,79,290/- were raised in A.Y. 2013- 14, which should have been added in the income of the assessee. Thus the Learned Pr. CIT opined that the assessment order passed by the AO was erroneous and prejudicial to the interest of the Revenue. Accordingly, the learned Pr. CIT issued notice u/s 263 of the Act to the ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... hearing in the absence of the assessee and is being decided on the basis of material available on record. 4. The learned CIT(DR) supported the order of the Ld. Pr. CIT passed u/s 263 of the Act. He submitted that the assessee failed to point out that AO had examined all the issues and the assessment order was not erroneous and prejudicial to the interest of Revenue. 5. We have heard learned ..... X X X X Extracts X X X X X X X X Extracts X X X X
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