TaxTMI 
TaxTMI 
2013 (4) TMI 62
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.... appeal emanating from the order of Ld. CIT-I, Baroda dated 31-03-2009 u/s 263 of the I.T. Act. The Ld. AO scrutinized the case u/s 143(3) of the I.T. Act and completed the assessment on 31-10- I.T.A. No.1776/Ahd/2009 A.Y. 2004-05 2006 wherein the gross additions were made at Rs. 3,53,94,191/- and revised loss calculated at Rs. 2,59,31,768/- against return loss of Rs. 6,13,25,959/-. The Ld. A.O. h....
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....full amount had been added back in computation of income by the assessee. The Ld. CIT-DR fairly accepted the facts. We have verified the fact and this interest has already been added back by the appellant in computation of income. Thus, to that extent this order of the AO is not erroneous and prejudicial to the interest of justice. 3. The ld. CIT observed that on perusal of balance sheet liabil....
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....s 263 on this issue is tantamount to change of opinion which is not permitted under the law as held by the various high courts on this issue. 5. Ground No. 4 is directing to the A.O. that Rs. 6,38,91,300/- being retention amount billed but not due had not accounted by the assessee which has been accepted by the Commissioner of Income-tax by passing the rectification order and allowed the assess....