9911796707
TMI Blog2021 (8) TMI 1396X X X X Extracts X X X X X X X X Extracts X X X X ..... all the cases, therefore with the consent of parties all the appeals are clubbed, heard and are decided by common order. For appreciation of facts appeal for A.Y. 2014-15 in ITA No. 41/RPR/2021 has been treated as lead case. The assessee has raised the following grounds of appeal:- "1. The order passed by ld. Pr.CIT is illegal, authorities below initio void & unsustainable as the same has been passed without giving any opportunity of hearing to assessee, contrary to mandatory requirement of law. Consequent revision order is illegal & is liable to be quashed/annulled. 2. The assessment order passed by AO is neither erroneous nor prejudicial to the interest of Revenue. Ld. Pr.CIT erred in invoking the provisions of sec. 263 and in setti ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... are attracted. The ld. PCIT also noted that there is a difference of sale consideration and value determined by Stamp Valuation Authority in respect of 12 such persons of Rs. 33.02 lakhs and that the AO failed to verify and applying the correct law. The ld. PCIT considered the reply of the assessee and the same is not satisfactory. The ld. PCIT set aside the assessment order and directed to verify the sale deed for the year under consideration and pass the assessment order afresh by giving adequate opportunity to the assessee. Aggrieved by the order of ld. PCIT the assessee has filed the present appeal before this Tribunal. 3. We have heard the submissions of ld. Authorized Representative (AR) for the assessee and the ld. Departmental Repr ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... he assessee. We, instead of going on the merit and demerit of the issues identified by ld. PCIT for revision find that the ld. PCIT passed the order in a hasty manner and without giving fair and proper opportunity. Therefore we deem it appropriate to restore the case back to the file of ld. PCIT to decide the issues identified by him afresh after giving opportunity of hearing to the assessee. 6. As recorded above, the assessee has raised similar contention and grounds of appeal as raised in the appeal for A.Y. 2014-15 wherein we have restored the appeal for A.Y. 2014-15 to the restored appeal to the ld. PCIT. Therefore, appeals for remaining three subsequent years are also restored back to the file of the ld. PCIT with similar observation. ..... X X X X Extracts X X X X X X X X Extracts X X X X
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