TaxTMI 
TaxTMI 
2022 (12) TMI 383
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....2078366(1) /1032078792(1) dated 31.03.2021 for the Assessment Year (A.Y.) 2016- 17. Since the grounds raised in these appeals are common, these appeals are clubbed, heard together and a common order is being passed and the facts are extracted from I.T.A.113/Viz/2021, for the sake of convenience as under. 2. Brief facts of the case are that the assessee is an individual, filed her return of income for the A.Y.2016-17, admitting total income of Rs.4,13,280/-. Later on, the case was selected for limited scrutiny under CASS and statutory notices u/s 143(2) and 142(1) of the Income Tax Act, 1961 (in short 'Act') were issued, calling for certain information. On examination of the information filed by the assessee, the Assessing Officer(AO) compl....
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....en submissions before the Ld.Pr.CIT as follows : "In this connection, I hereby bring to your kind notice that I have already submitted electronically all the information, details, evidences and documents in support of purchase of 1/3 share of immovable property during the previous year 2015-16, relevant to the Asst.Year 2016-17 at the time of assessment proceedings. The then Learned Assessing Officer also examined my case thoroughly and verified information, details, evidences and documents submitted by me and passed order u/s 143(3) of the I.T.Act by accepting the income admitted by me on 22.11.2018. So, at this point of time, it is not at all justified to revise my assessment u/s 263 of the I.T.Act, as I have discharged my onus complete....
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...., except stating that the cash paid / deposited was out of the balance available in her books, had not submitted any documentary evidence to substantiate her claim and the AO had not verified the same and hence, the assessment order passed by the AO is erroneous and prejudicial to the interest of the revenue. The Ld.Pr.CIT directed the AO to redo the assessment after gathering all necessary evidences and after causing proper verification and pass consequential order accordingly after giving opportunity of being heard to the assessee. 4. Aggrieved by the order of the Ld.Pr.CIT, the assessee preferred appeal before the Tribunal and raised the following grounds : 1. The impugned order dated 31.03.2021 passed by the Hon'ble Principal CIT-1, ....
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....al are related to initiation of revisionary proceedings by the Ld.Pr.CIT u/s 263 of the Act. 6. The Ld.AR argued that the assessee had uploaded all the information, details, evidences and documents as called for by the then Ld. AO during the course of assessment proceedings and also uploaded the details of payments made by the assessee towards purchase of 1/3 share of property in the F.Y.2015-16 and the details of sources into the mail ID of the Ld.Pr.CIT. The assessee had produced the books of account relating to the F.Y.2015-16, relevant to the A.Y.2016-17 before the Ld.AO in which the impugned purchase of immovable property to the extent of 1/3rd share was reflected. The Ld.AR further submitted that the AO has examined the relevant info....