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TMI Blog2023 (1) TMI 1340X X X X Extracts X X X X X X X X Extracts X X X X ..... y the revised return of income which was filed within the prescribed time period. The case was selected for scrutiny on two issues, which the assessee successfully explained before the AO, therefore, as supposed to assess the income as per the revised return of income. If the AO wanted to scrutinise any other issue also including the withdrawal of interest income, which the assessee claimed to be erroneously offered, the AO could have got converted the limited scrutiny assessment into full assessment by getting permission from the competent authority. Even otherwise, AO has merely taken the returned income as per original return of income without making any disallowance in respect of above issue in the revised return of income. Theref ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... CIT(A) failed to observe that the Assessing Officer (in short, AO) has not assessed the income at Rs.2,52,03,200/- in its Order under Section 143(3), but has considered the returned income at Rs. 2,52,03,200/- emanating from the original return filed on 30.10.2015, and thereupon conducted the limited-scrutiny' assessment, assessing the income at Rs.2,52,64,580/- 3. For that the CIT(A) failed to observe that in the Order under Section 143(3) the A.O has expressly recorded that the assessment is completed considering the original return of income submitted by the assessee...without dwelling into the details of revised return and reason thereof... , and therefore, the question of non- acceptance of Or interference with the particula ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... of Rs.61,388/- u/s 14A of the Act. However, the Assessing Officer while completing the assessment taken the assessed income as per the original return filed and not as per the revised return stating that the assessee s original return of income was selected for scrutiny assessment. 5. In appeal, the ld. CIT(A) deleted the disallowance made by the Assessing Officer u/s 14A of the Act. However, the ld. CIT(A) upheld the action of the Assessing Officer in treating the returned income as per original return of income at Rs.2,52,03,200/- as against the revised returned income of Rs.1,31,03,060/-, holding that while the assessee had revised the return, the books of account were not revised and that the Assessing Officer was justified in pickin ..... X X X X Extracts X X X X X X X X Extracts X X X X
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