Revision u/s 263 by CIT - Addition of unexplained cash credit...
CIT Challenges Assessment: Section 263 Revision on Unexplained Cash Credit u/s 68 May Affect Revenue Interests.
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Income TaxOctober 1, 2021Case LawsAT
Revision u/s 263 by CIT - Addition of unexplained cash credit u/s 68 - AO has deemed it fit and proper to treat the cash deposits as the business receipts of the assessee and to estimate the income thereon at 12%. Therefore, it cannot be said that the assessment order u/s 143(3) r.w.s. 263 dated 27.10.2014 is erroneous. By not bringing to tax the entire cash deposits u/s 68 of the Act, the assessment order may be said to have been prejudicial to the interest of the Revenue. But, for a valid revision, both the conditions i.e. the assessment order being erroneous and also being prejudicial to the interest of the Revenue are to be satisfied. - AT
Revision u/s 263 by CIT - Addition of unexplained cash credit u/s 68 - AO has deemed it fit and proper to treat the cash deposits as the business receipts of the assessee and to estimate the income thereon at 12%. Therefore, it cannot be said that the assessment order u/s 143(3) r.w.s. 263 dated 27.10.2014 is erroneous. By not bringing to tax the entire cash deposits u/s 68 of the Act, the assessment order may be said to have been prejudicial to the interest of the Revenue. But, for a valid revision, both the conditions i.e. the assessment order being erroneous and also being prejudicial to the interest of the Revenue are to be satisfied. - AT
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