2022 (7) TMI 1543

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....s De, Adv. For the Appellant in Item No.22: Mr. Prithu Dudharia, Adv. For the Appellant in Item No.24 : Mr. S. Roy Chowdhury, Adv. For the Respondent : Ms. Swapna Das, Mr. Siddhartha Das, Advs. The Court : This appeal by the revenue filed under section 260A of the Income Tax Act, 1961 [the Act, for brevity] is directed against the common order passed by the Income Tax Appellate Tribuna....

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....mmissioner of Income Tax passed under Section 263 of the Income Tax Act, 1961 who legally assumed jurisdiction as the assessment order of Assessing Officer is erroneous and prejudicial to the interest of Revenue? We have heard the learned standing Counsel appearing for the appellants and the respondents. The short question involved in these appeals is whether the Principal Commissioner of In....

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....l and in our considered view after taking note of the various decisions of the Hon'ble Supreme Court it was rightly pointed out that section 263 of the Act does not permit substituting one opinion for another. That apart, the tribunal has specifically recorded a factual finding that the assessee had produced all necessary details of the purchase, sales, audited books of accounts, quantity details,....