2022 (6) TMI 686

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....e assessment year 2015-16 was filed on 15.09.2015 declaring total income of Rs.2,96,460/-. Against the said return of income, the assessment was completed by the Income Tax Officer, Ward- 2, Dhule ('the Assessing Officer') vide order dated 20.12.2017 passed u/s 143(3) of the Income Tax Act, 1961 ('the Act') at total income of Rs.7,26,150/- after making (i) addition on account of business receipt of Rs.2,04,069/- and (ii) addition on account of opening cash balance of Rs.2,25,618/-. While matter stood thus, the PCIT on examination of the assessment record formed an opinion that the assessment order passed by the Assessing Officer is erroneous and prejudicial to the interests of the Revenue for the following reasons :- (i) The Assess....

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..... 5. It is submitted that the assessment was selected for scrutiny for the purpose of verifying the cash deposits in bank account and the assessment order cannot be termed as "erroneous and prejudicial to the interests of the Revenue" as the Assessing Officer after due examination of the issues which are sought to be revised by the ld. PCIT had passed the assessment order. 6. On the other hand, ld. Sr. DR placing reliance on the order of the lower authorities submitted that despite due service of notice, the appellant had not availed the opportunity of representing the matter before the ld. PCIT by responding to the show-cause notice issued u/s 263 of the Act. There is no glory mistakes in the order of revision. Thus, it is submitted ....