2025 (3) TMI 882

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..... rd to the claim of deduction u/s 10AA HELD THAT:- It is accepted that a reassessment order under Section 148 r/w Section 143(3) of the 1961 Act was passed. Addition was not made for the first reason. In the given facts, the assertion by the Revenue that inquiry and verification in re the bank account was not made is ex-facie incorrect. This being the position, this is not a case of failure to in .....

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..... Kumar For the Petitioner(s) : Mr. Raghavendra P Shankar, A.S.G., Mr. Raj Bahadur Yadav, AOR, Mr. Karan Lahiri, Adv., Mr. Santosh Kumar, Adv., Mr. Piyush Beriwal, Adv. And Mr. Udit Dedhiya, Adv. For the Respondent(s) : None ORDER Delay condoned. This special leave petition is misconceived and is completely contrary to the law pertaining to Section 263 of the Income Tax Act, 1961. "1961 Act", f .....

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..... ue can argue that it is a case of wrong conclusion and decision in the reassessment proceedings. Therefore, to exercise jurisdiction under Section 263 of the 1961 Act, the Commissioner of Income Tax should have examined the merits and only on reaching a finding that the re-assessment order was erroneous and prejudicial to the interest of the Revenue made an addition. This is not a case of 'no inq .....

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