2022 (7) TMI 484

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....eturn of income for the AY 2015-16 admitting a taxable income of Rs. 13,71,500/-. Subsequently, the case was selected for complete scrutiny under CASS and statutory notices U/s. 143(2) and 142(1) were issued and served on the assessee called for certain information. In response to the notices, the assessee submitted the information called for and produced the relevant records before the Assessing Officer. The Assessing Officer considering the submissions made by the assessee assessed the income at Rs. 40,85,220/-. Thereafter, the Ld. Pr. CIT under the powers vested U/s. 263 of the Act issued a show cause notice dated 7/2/2020 considering the order passed by the AO u/s. 143(3) is prima facie erroneous in law and prejudicial to the interests ....

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....neous and such a finding has no legs to stand. 5. For these and other reasons that are to be urged at the time of hearing of the appeal the appellant prays that the order passed by the Ld. Pr. CIT is erroneous both on facts as well as in law, therefore the same needs to be set aside in the interest of justice." 4. Before us, the assessee has also raised the additional grounds of appeal as follows: "The Ld. Pr. CIT under the facts and circumstances of the case, is not correct in directing the AO to disallow interest of Rs. 33,63,521/- (12% on Rs. 2,80,29,345/-) when the AO in the order passed U/s. 143(3) of the Act has rightly disallowed interest of Rs. 96,616/- calculated at 12% on the net amount of interest free advances given of Rs. ....