2022 (3) TMI 607

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....ition explaining the cause of the delay. The main cause of the delay according to assessee was due to the Covid-19 pandemic and relying on the decision of the Hon'ble Supreme Court suo moto in Misc. Application N. 665/2021 in SMW(C) No. 3/2020 extending the limitation in filing cases by order passed under Article 141 of the Constitution of India dated 27.04.2021, we are inclined to condone the delay and admit the appeal for hearing. 3. The main grievance of the assessee is against the action of the Ld. Pr. CIT in exercising his revisional jurisdiction without satisfying the condition precedent as prescribed u/s. 263 of the Act i.e. without validly holding that the order of the AO is erroneous as well as prejudicial to the interest of the r....

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....t, it has been brought to our notice by the Ld. AR that the Ld. Pr.CIT has admitted the following facts in the impugned order which is reproduced as under: "On examination of the assessment records in the case of M/s Bhajyaraaj Vyapar Pvt. Ltd. PAN: AABCB4516G, AY 2011-12 it has been observed that in this case credible information was available that the assessee under consideration had obtained accommodation entries to the tune of Rs. 50,00,000/- from different entities during FY 2010-11 and the case was reopened for scrutiny by issuing notice u/s 148 of the I.T.Act, 1961. Subsequently, order u/s 147/143(3) was passed on 29.01.2016 wherein an addition of Rs. 25,00,000/- was made by the Assessing Officer instead of the purported entry of R....