2019 (9) TMI 1651

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....see raised the following grounds of appeal: 1) The order of the learned Principal Commissioner of Income tax,Central-2, Chennai is Wrong, illegal and is opposed to law and facts of the case. 2) The learned Principal Commissioner of Income Tax, Central-2 Chennai ought to have seen that the order of assessment is not erroneous and that the learned CIT can assume jurisdiction under section 263 only if the twin condition of the assessment order being erroneous and pre-judicial to the interest of the revenue is satisfied. 3) The learned Principal Commissioner of Income Tax, Central-2 while passing orders under section 263 erred in giving a specific direction of Rs.3,44,77,220/- in the hands of the appellant in a precon....

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.... 3. Briefly the facts of the case are that the assessee is an individual. The return of income for the AY 2011-12 was filed on 25.09.2011 declaring total income of Rs.15,98,04,415/-. Against the said return of income, the assessment was completed by the AO vide an order dated 30.03.2014 passed u/s.143(3) of the IT Act. Subsequently, the assessment was reopened u/s.148 of the IT Act stating that the amount of Rs.3,47,77,200/- received from Lebara Mobile, UK, and (an amount of Rs.54.00 lakhs received from M/s. Photon Kathas Production Pvt. Ltd.,) had escaped assessment of tax, thereafter, proposed to re-assess the same. During the course of re-assessment proceedings, the assessee made detailed submissions before the AO stating that the contr....