2024 (9) TMI 207

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....gainst the learned PCIT's revision directions holding the Assessing Officer's regular assessment dated 22.09.2021 as an erroneous one causing prejudicial to interest of Revenue for the sole reason that latter had not assessed the assessee's alleged suppressed professional receipts; declared as additional income, during the course of survey dated 26.02.2019, u/s 115BBE of the Act. 3. Shri Puranikh vehemently argued that the PCIT herein has erred in law and on facts in assuming section 263 revision's jurisdiction thereby directing the Assessing Officer to invoke section 115BBE qua assessee's professional receipts declared during survey. He further invites our attention to the case records that the assessee had duly filed all the relevant det....

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....rtion of the section 69 is read as under: "69. Unexplained investments. Where in the financial year immediately preceding the assessment year the assessee has made investments which are not recorded in the books of account, if any, maintained by him for any source of income, and the assessee offers no explanation about the nature and source of the investments or the explanation offered by him is not, in the opinion of the [Assessing Officer] [ Substituted by Act 4 of 1988, Section 2, for "Income-tax Officer" (w.e.f. 1.4.1988).], satisfactory, the value of the investments may be deemed to be the income of the assessee of such financial year." During the assessment proceedings, the AO has failed to consider the same by adding the whole ....