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TMI Blog2024 (7) TMI 959X X X X Extracts X X X X X X X X Extracts X X X X ..... also been answered substantiated with documentary evidence. AO in the course of Face Less Assessment would have obviously had this documentary evidence verified by the Verification Unit. There is no allegation by ld CIT(E) that these documents and evidences were not verified by the Verification Unit of the FaceLess Assessment Proceedings. The issues which have been raised by ld CIT(E) in his order u/s. 263 have clearly been examined by the AO in the course of assessment proceedings, it cannot be said that there has been no application of mind by the AO. A perusal of the order of the ld CIT(E) does not show as to what is the specific error which has been done by the AO has led to prejudice the interest of the revenue. Now, if at all, the in ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ns by issuance of show cause notice, wherein, issues of accumulation of income by the Trust had also been examined. It was the submission that notice u/s. 143(2) of the Act came to be issued on 22.9.2019. Further, notice u/s. 142(1) of the Act came to be issued on 25.11.2020, wherein, various details as mentioned in the annexures thereto were called for, copy of the same reads as follows: Government of India Ministry of Finance Income Tax Department, National e-Assessment Centre, Delhi To Trident Academy of Creative Technology, A-127, Sahidnagar, Bhubaneswar. Khurdha-751007, Orissa PAN No.AABTT0273 H Asst.Yr-2018-19 Dt.25.11.20 Din; ITBA/AST/F/R142910/2020-21/1028734267(1) Notice under sub-section (1) of Section 142 of the Income Tax Act,19 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ions alongwith proofs/supporting documents for the utilizations. 6. Details of voluntary contributions other than corpus of INR 92,12,637/- alongwith ledger copy/copies. 7. Details source of income and activities from which income is arising with respect to aggregate income of INR 10,32,81,661/- as disclosed in the Income tax Return alongwith ledger copies of the same. 8. Details of amounts applied-revenue to the extent of INR 4,37,84,061/- in the income tax return along ledger copies. 9. Details of amount accumulated/set apart of INR 1,39,23,764/- as per income tax return. Mode of investing the said accumulated amount alongwith proof/supporting documents. 10. Details of amount accumulated/set apart of INR 5,00,00,000 apart from point 9 abo ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ferential interest income, the assessee has clearly mentioned that the interest received was actually Rs. 1,10,63,734/- whereas as per the income and expenditure account, the receivable was Rs. 1,29,78,999/-. It was the submission that the said interest income of Rs. 19,15,625/- was nothing but the interest that was liable to be received by the assessee as accrued interest on various deposits maintained by the assessee. It was the submission that this was specifically queried by the Assessing Officer and replies by the assessee were examined in-depth by the Assessing Officer and accepted in the scrutiny assessment. It was the submission that the ld CIT(E) when called for the record of the assessee, would have noticed the evidence in the fil ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... wered substantiated with documentary evidence. The Assessing Officer in the course of Face Less Assessment would have obviously had this documentary evidence verified by the Verification Unit. There is no allegation by ld CIT(E) that these documents and evidences were not verified by the Verification Unit of the Face Less Assessment Proceedings. The issues which have been raised by ld CIT(E) in his order u/s. 263 have clearly been examined by the Assessing Officer in the course of assessment proceedings, it cannot be said that there has been no application of mind by the Assessing Officer. Further, a perusal of the order of the ld CIT(E) does not show as to what is the specific error which has been done by the Assessing Officer has led to p ..... X X X X Extracts X X X X X X X X Extracts X X X X
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