2024 (10) TMI 1579

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.... 2. The Assessing Authority has passed scrutiny assessment order under Section 143(3) of the Income Tax Act on 30.12.2019, where, the assessing authority has passed a very cryptic order consisting of two paragraphs and for the sake of convenience, the assessment order dated 30.12.2019 in entirety is extracted hereunder: "The Assessee has filed her original return of income for the assessment year 2017-18 on 29.11.2017 admitting a total income of Rs. 64,70,050/-. Again, she has filed her revised return of income on 26.06.2018 admitting a total income of Rs. 64,70,050/-. The case has been selected for scrutiny under CASS. Accordingly, a notice u/s.143(2) dated 10.08.2018 has been issued to the Assessee. Subsequently, notices u/s.142(....

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....ad not been verified and recorded in the assessment order for the huge increase of share premium and also the cash deposits made by the assessee during the demonetization period to the extent of Rs. 6,51,42,171/- also had been noticed. However, the source has also not been verified and recorded in the assessment order. 4. Moreover, the very assessment order passed by the assessing authority under Section 143(3) itself has been a cryptic order and has been extracted herein above. Therefore, the revisional authority having invoked Section 263(3) of the Act passed an under under revision dated 29.03.2022, whereby the assessment order had been set aside and had been remitted to the assessing officer to make a detailed enquiry and pass orders....

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....as been raised before the Tribunal and therefore on the same question of law, this appeal also has to be entertained and to be decided, he contended. 9. We are not impressed with the submission made by the learned counsel for the appellant for the reason that, insofar as the scrutiny assessment that has been made by the assessing officer is concerned, as we have seen the order passed by the assessing officer under Section 143(3) of the Act on 30.12.2019, where nothing has been stated as to what are all the inputs and documents which have been sought for under the scrutiny assessment order from the assessee and what are all the documents which have been filed by the assessee, whether those documents have been perused and verified and only....