TaxTMI 
TaxTMI 
2022 (3) TMI 423
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....T under section 263 of the Act. 3. The facts in brief are that the assessment u/s 143(3) of the Act was framed vide order dated 19.12.2017 by making an addition of Rs. 5,96,25,721/- in respect of sale consideration of shares u/s 68 of the Act and Rs. 35,77,543/- on account of commission paid for taking accommodation entries. The Ld. PCIT after examining the assessment records came to the conclusion that AO has not examined the unsold shares of 10,46,400 of M/s. Greencrast Financial Services Ltd. while the shares sold during the year of Rs. 5,96,25,721/- were duly disclosed in the return of income. Accordingly, the Ld. PCIT, exercising revisionary jurisdiction by issuing notice under section 263 of the Act dated 15.03.2021 giving a show cau....
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....submitted that the remaining unsold shares of 10,46,400 which were remaining unsold at the financial year end were duly disclosed in the balance sheet and were sold in the subsequent year. The Ld. A.R. submitted that in view of the above facts, the issue is already examined by the AO and only possible view taken in the assessment order, therefore the assessment order can not be termed as erroneous and prejudicial to the interest of the revenue and may kindly be quashed. 5. The Ld. D.R., on the other hand, relied on the order of Ld. PCIT by submitting that no prejudice to be caused to the assessee in case the assessment order is revised as the assessee is being given fresh opportunity to explain his case before the AO. Accordingly, the Ld. ....