2022 (4) TMI 1465

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....or the Appellant Mr. Aryak Dutt, Adv. For the Respondent Mr. Pratyush Jhunjhunwala, Adv. Mr. S. Rudro, Adv. ORDER Heard Mr. Aryak Dutt, learned Standing Counsel appearing for the appellant/revenue and Mr. Pratyush Jhunjhunwala, learned Counsel appearing for the respondent/assessee. This application has been filed for condonation of delay of 172 days in filing the appeal. By order dated....

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.... the totalities of the facts and circumstances raises substantial question of law? b) Whether on the facts and the circumstances of the case, the Learned Tribunal has erred in law or in fact in not appreciating that in a proceeding under Section 263A of the Income Tax Act, 1961, the CIT(Appeals) must come to a conclusion that the assessment by the assessing officer has to be erroneous and....

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....scussed with the assessee by the Assessing Officer and several details have been called for. After examining the details the Assessing Officer completed the assessment under Section 143(3) dated 4th March, 2015. In the opinion of the Principal Chief Commissioner of Income Tax (PCIT), the assessment was erroneous and prejudicial to the interest of the revenue and therefore, proceedings were initiat....

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.... Assessing Officer and the details contained in annexures in support of the advances received giving names of each of the party and these records were also placed before the Tribunal in the form of a paper book. Further, the Tribunal noted that the assessee had filed tax audit report under Section 44AB of the Act in Form no.3CA along with the particulars and also furnished Form no.3CD. Further, th....