9911796707
TMI Blog2023 (6) TMI 174X X X X Extracts X X X X X X X X Extracts X X X X ..... ) of the Act by the PCIT is quashed. Decided in favour of assessee. - I.T.A. No. 920/DEL/2021 - - - Dated:- 31-5-2023 - Shri Anil Chaturvedi, Accountant Member And Shri Yogesh Kumar U.S., Judicial Member For the Assessee : Shri V. K. Bindal, CA And Mrs. Rinki Sharma, ITP For the Department : Shri Kanwaljit Singh, CIT(DR) ORDER PER YOGESH KUMAR U.S., JM This appeal is filed by the assessee against the order dated 15/03/2021 passed by the Office of the Pr. Commissioner of Income Tax (hereinafter referred to (Appeals) Faridabad- for assessment year 2010-11. 2. The assessee has raised the following grounds of appeal :- 1. That learned PCIT, erred in law and facts by initiating the provisions of Sec-263 of ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... alid, bad in law and void-ab-initio. 3. Brief facts of the case are that, the assessment proceedings was completed u/s 143(3)/147 of the Act vide order dated 13/11/2017 by the A.O. at an income of Rs. 6,60,820/- by making an addition of Rs. 25,000/-. The Ld. PCIT on perusal of the assessment record of the assessee for the Assessment Year 2010-11 noticed following discrepancies:- The assessee was engaged in the business of trading of petrol with the name and style of M/s Nirmal Filling Station . The assessee has made an addition of Rs. 20,59,000/- in the capital account of his concern during Financial Year 2009-10 but not explanation was submitted during the assessment proceedings. The Ld. PCIT was of the opinion that, the ass ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... after passing the assessment order dated 13/11/2017 u/s 143(3)/147 of the Act the A.O. by invoking Section 154 of the Act, made addition of Rs.20,59,000/- in following manners:- Return declaring income of Rs. 6,35,820/- was filed by the assessee on 17/04/2017 and assessment in this case was completed u/s 147/143(3) of the Act on 13/11/2107 at an income of Rs.6,60,820/- by making addition of Rs.25,000/- on account of unvouched expenses. Later on, it was noticed that the assessee engaged in the business of trading in petrol in the name and style of M/s Nirmal Filling Station. In the capital account of this concern an addition of Rs.20,59,000/- has been made in F.Y. 2009-10 and the same was not considered at the time of passing of as ..... X X X X Extracts X X X X X X X X Extracts X X X X
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