2022 (9) TMI 303

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....has raised the following grounds of appeal: - "1. The ld. Pr. CIT erred on facts and in law in initiating revision proceedings u/s 263 without appreciating that order passed by the Assessing Officer was neither erroneous nor was prejudicial to the interests of revenue. 2. The ld. Pr. CIT erred on facts and in law in setting aside the order passed by Assessing Officer by invoking provisions of section 263 of the Act. 3. The ld Pr. CIT erred on facts and in law in holding that an amount of Rs.1,84,80,600/- is liable to be assessed u/s 69 on the ground that value of land to this extent was not recorded in the books without appreciating that entire purchase cost of land is duly recorded in the books and was subjected ....

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.... the assessee-firm has made Power of Attorney vide No.3046/2012 dated 25.10.2012 registered with Subregistrar, Umbergaon in the name of one of its partners namely Jitendra Kunwerji Gala. As per this Power of Attorney, the assessee-firm was in possession of 2,73,543 square meter of agricultural land at Timbhi, Umbergaon, Valsad. However, the assessee-firm has shown the remaining land valued at Rs.1,84,80,600/- in its balance-sheet. The Assessing Officer was required to invoke the provisions of Section 68 of the Act for treating the value of the investment to the extent of Rs.1,84,80,600/-. • The Assessing Officer was required to invoke the provisions of Section 69 of the Act for treating the value of the investment to the extent....

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....e details of unsecured loans, confirmation of loan, carry forward and interest paid of such loans and the advances received during the assessment years 2008-09 to 2013-14 with complete details. The Ld. PCIT recorded that no details were furnished despite serving specific notices. The Ld. PCIT further recorded that the assessee furnished details vide its reply dated 19.03.2018 as recorded on pages 5 to 7of the order of Ld. PCIT. The Ld. PCIT recorded that assessee has no intention to provide complete details and justification of various issues raised in the notice under section 263 of the Act. The Ld. PCIT accordingly set aside the assessment order passed by Assessing Officer and directed the Assessing Officer to pass the fresh assessment or....