https://www.taxtmi.com/caselaws?id=450249 The ITAT Kolkata ruled in favor of the assessee, holding that the CIT's revision order under section 263 was unsustainable on three grounds. First, the second reassessment notice was invalid as it was issued after the four-year limitation period without the AO identifying specific undisclosed information. Second, the CIT failed to establish any specific error regarding the Rs. 15,00,000 loan acceptance by the AO. Third, the CIT's examination of unsecured loans should have been conducted during the original assessment under section 143(3) passed on 13.11.2014, and the two-year limitation period for section 263 proceedings had expired by the time the notice was issued in 2022. en-us Wed, 21 Feb 2024 00:00:00 +0530 Fri, 01 Mar 2024 07:32:10 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=450249 The ITAT Kolkata ruled in favor of the assessee, holding that the CIT's revision order under section 263 was unsustainable on three grounds. First, the second reassessment notice was invalid as it was issued after the four-year limitation period without the AO identifying specific undisclosed information. Second, the CIT failed to establish any specific error regarding the Rs. 15,00,000 loan acceptance by the AO. Third, the CIT's examination of unsecured loans should have been conducted during the original assessment under section 143(3) passed on 13.11.2014, and the two-year limitation period for section 263 proceedings had expired by the time the notice was issued in 2022. Case-Laws Income Tax Wed, 21 Feb 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=450249