TaxTMI 
TaxTMI 
2022 (12) TMI 780
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.... Officer (AO) dated 04.11.2019 under Section 143(3) of the Income Tax Act, 1961 (the Act) concerning AY 2017-18 was sought to be set aside for reframing assessment in terms of supervisory direct ions. 2. As per its grounds of appeal, the assessee has challenged the revisional act ion of the PCIT whereby the Assessing Officer (A.O.) was directed to pass the assessment order denovo after making enquiries on the points set out in the show cause notice and the revisional order. The assessee has challenged the assumption of jurisdiction by the PCIT under section 263 of the Act on the ground that the Assessment Order under revision is neither erroneous nor prejudicial to the interest of the Revenue. 3. Briefly stated, the assessee filed return ....
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....determining the tax liability on assessed income is clearly erroneous and prejudicial to the interest of the Revenue. The PCIT accordingly exercised its jurisdiction conferred under Section 263 of the Act and directed the Assessing Officer redo the assessment afresh having regard to the observations made in the revisional order. 6. Aggrieved by the revisional order passed by the PCIT, the assessee preferred appeal before the Tribunal to challenge the supervisory jurisdiction usurped by the PCIT under section 263 of the Act. 7. We have heard the rival submissions on the issue. On a broader reckoning, the contentions of the assessee are: i) The case was selected for 'limited scrutiny' and therefore the scope of the assessment was confined....
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....9 order dated 27.11.2019; Balvinder Kumar vs. PCIT (2021) 125 taxmann.com 83 (Delhi-Trib.) & Hill Queen Investment (P.) Ltd. vs. PCIT (2021) 127 taxmann.com 682 (Kolkata- Trib.) and was submitted that the co-ordinate bench of Tribunal have uniformly held that where the scope of scrutiny is limited to the issues raised, the revisional authority is not entitled unders.263 of the Act to examine the issue not specified in the limited scrutiny assessment . 9. On appraisal of the evidences placed before us, we find that vide notice dated 10.08.2018 specific queries were raised by the AO in relation to the issue raised for the purposes of limited scrutiny, i.e., 'Payment of tax in cash during demonetization period'. In response, the assessee has ....