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TMI Blog2024 (2) TMI 694X X X X Extracts X X X X X X X X Extracts X X X X ..... . R. Kumar, Accountant Member And Sh. Anubhav Sharma, Judicial Member For the Assessee : Sh. Dev Raj Sharma, Adv. For the Revenue : Sh. N.S. Jangpandi, CIT-DR ORDER PER DR. B. R. R. KUMAR: - The present appeal has been filed by the assessee against the order of ld. PCIT, Dehradun dated 18.03.2021. 2. The assessee has raised the following grounds of appeal:- 1. That the facts and circumstances of the case, the learned Pr.CIT has erred both on facts and in law in assuming powers us 263 of the Income Tax Act holding the assessment order dated 13.12.2017 as erroneous and prejudicial to the interest of the revenue on the ground that the order was passed without making inquiries/verification which should have bee ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... read as under: 263. (1) The 99 [Principal Chief Commissioner or Chief Commissioner or Principal Commissioner] or Commissioner may call for and examine the record of any proceeding under this Act, and if he considers that any order passed therein by the Assessing Officer 1 [or the Transfer Pricing Officer, as the case may be,] is erroneous in so far as it is prejudicial to the interests of the revenue, he may, after giving the assessee an opportunity of being heard and after making or causing to be made such inquiry as he deems necessary, pass such order thereon as the circumstances of the case justify, 2 [including, (i) an order enhancing or modifying the assessment or cancelling the assessment and directing a fresh assessment; or ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... rder referred to in this sub-section and passed by the Assessing Officer 3 [or the Transfer Pricing Officer, as the case may be,] had been the subject matter of any appeal filed on or before or after the 1st day of June, 1988, the powers of the Principal Commissioner or Commissioner under this sub-section shall extend and shall be deemed always to have extended to such matters as had not been considered and decided in such appeal. Explanation 2. For the purposes of this section, it is hereby declared that an order passed by the Assessing Officer 3 [or the Transfer Pricing Officer, as the case may be,] shall be deemed to be erroneous in so far as it is prejudicial to the interests of the revenue, if, in the opinion of the Principal Chie ..... X X X X Extracts X X X X X X X X Extracts X X X X
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