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TMI Blog2023 (11) TMI 976X X X X Extracts X X X X X X X X Extracts X X X X ..... e of the opinion that the assessment order is very cryptic without speaking about the verifications made by the AO for which the return filed by the assessee was selected for Scrutiny . Against the notice u/s 263 of the Act, before the ld. PCIT, the assessee has explained that the assessee was engaged in real estate business and sold plots during the year for a total consideration and the same has not been reflected in the bank account of the assessee for the reason that the sale proceeds of the plots are cash sales only. On an overall examination of the records, PCIT has correctly observed that no proper examination/verification was done by the AO while passing the assessment order u/s 143(3) on the above issue and the AO had passed ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... alling for details. On verification of the details filed by the assessee along with return of income, the Assessing Officer found that there was a difference in closing stock compared to the return of income of the previous year and cash deposits reported in SFT-14. When the Assessing Officer questioned about the correct valuation of stock, the AR of the assessee was unable to substantiate, but, filed a letter from the assessee on 16.03.2018 in which the assessee has agreed a sum of ₹.5,00,000/- towards his business income. Accordingly, the Assessing Officer has completed the assessment under section 143(3) of the Act dated 23.05.2018 assessing total income of the assessee at ₹.15,32,334/- by making addition of ₹.6,33,334/ ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ons of section 263 of the Act cannot be invoked by the ld. PCIT by observing that the Assessing Officer has not made sufficient enquires before completing the assessment. 6. On the other hand, the ld. DR has submitted that in this case, the Assessing Officer, without making any enquiry/investigation, simply accepted the addition agreed by the assessee. Therefore, the ld. PCIT has correctly exercised the powers conferred under section 263 of the Act and also submitted that the order passed by the Assessing Officer is erroneous and prejudicial to the interest of the Revenue. 7. We have heard both the sides, perused the materials available on record and gone through the assessment order as well as revision order passed under section 263 ..... X X X X Extracts X X X X X X X X Extracts X X X X
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