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2023 (9) TMI 550

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..... neous and prejudicial to the interest of Revenue was wrong. As observed that the assessment of the assessee was taken under Limited scrutiny under CASS for verifying the following CASS reasons Large Deduction Claimed u/s. 57, Higher Turnover Reported in Service Tax Return as Compared to ITR . Notice was issued under section 143(2) of the Act in which a specific query was put forth regarding t .....

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..... challenging the order dated 22.03.2023 passed by the Income Tax Appellate Tribunal, Rajkot (for short the Tribunal ) in ITA No. 118/ RJT/2022 for the assessment year 2017-18. 3. The following substantial questions of law have been raised for the consideration of this court: (i) Whether the Hon ble Tribunal was justified in quashing the order u/s. 263 of the Income Tax Act of Ld. PCIT when .....

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..... conducted as per order of the Hon ble Supreme Court in case of the Commissioner of Income Tax vs. M/s. Paville Projects Pvt. Ltd. (CA No. 6126 of 2021 (SC))? 4. It was the case of the Revenue that on verification of details when the case of the assessee was selected for scrutiny for reasons that large deduction under the Income Tax Act, 1961 (for short the Act ) was claimed by the assesse .....

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..... ribunal has reproduced the response to the notice. 5. Reading the order of the Tribunal especially paragraphs no. 4, 5 6 indicate that in the set of facts, the contention of the authority is that the AO s order was erroneous and prejudicial to the interest of Revenue was wrong. It was observed that the assessment of the assessee was taken under Limited scrutiny under CASS for verifying the f .....

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