Liberal construction of sufficient cause justifies condonation of inordinate delay where criminal proceedings and jail confinement explained the defau...
Revision u/s 263 - unexplained cash credit u/s 68 - the documents were very much available on ‘record’ when the ld PCIT examined this assessment folder. When all these details were already on record, it is reasonably expected from ld PCIT to look into those details (as already forming part of record) before arriving at any conclusion that whether the said loan was squared up during the year or not. - PCIT had totally proceeded on incorrect assumption of fact - AT
Revision u/s 263 - unexplained cash credit u/s 68 - the documents were very much available on ‘record’ when the ld PCIT examined this assessment folder. When all these details were already on record, it is reasonably expected from ld PCIT to look into those details (as already forming part of record) before arriving at any conclusion that whether the said loan was squared up during the year or not. - PCIT had totally proceeded on incorrect assumption of fact - AT
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