2022 (3) TMI 258

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....ndent Through: Mr.Aseem Chawla, Advocate. J U D G M E N T MANMOHAN, J (Oral): C.M.No.32806/2021 Keeping in view the averments in the application, the same is allowed and the delay in filing the present appeal is condoned. The appeal is taken on record. Accordingly, the application stands disposed of. ITA 146/2021 1. Present Appeal has been filed challenging the order dated 14t....

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....d order has given detailed reasons as to why the exercise of jurisdiction by the Commissioner of Income Tax (Exemptions) under Section 263 of the Act was not warranted in the present case. The relevant portion of the said order is reproduced hereinbelow:- "8. .......As regards the cash deposit of Rs. 6.05 crores in the Bank Account of assessee, the assessee produced complete details befor....

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.... 8.2. .......The second issue is with regard to amount of two entries Rs. 1.5 crores, which assessee has explained that Rs. 1.56 crores was the amount received on sale of land through cheque, therefore, it could not be an undisclosed income of the assessee. Further, interest have been received of Rs. 64,28,241/- which is also appearing in Form-26AS and disclosed to the Revenue Department as w....

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....Ld. CIT(E) in proceedings under section 263 of the Income Tax Act, 1961. Therefore, it is not fit case of invocation of jurisdiction under Section 263 of the Income Tax, 1961......." 4. This Court is in agreement with the findings recorded by the ITAT that since the total receipts of fees had been disclosed in the income and expenditure account, the same cannot be considered as unaccounted inco....