2025 (6) TMI 883

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....3 of the Income-tax Act, 1961 [hereinafter referred to as "the Act"], for the Assessment Year (AY) 2014-15. 2. The Assessee has taken following grounds of appeal :- "1. The Ld. PCIT has grossly erred in law and on facts in assuming jurisdiction u/s.263 of the Act on the erroneous ground that the impugned assessment order is erroneous in so far as it is prejudicial to the interest of the revenue. 2. The Ld. PCIT has grossly erred in not appreciating that in order to invoke s.263, two conditions must be fulfilled viz. the impugned assessment order must be erroneous and that error must be prejudicial to the interest of the revenue. In the present case, Ld. AO has passed the reasoned assessment order after analyzing all details and theref....

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....ndividual, filed her return of income for the year under consideration on 31.07.2014 declaring total income of Rs. 63,21,444/-. The case was reopened u/s. 147 of the Act. Pursuant to reopening under section 147 of the Act, the assessee filed a revised return on 16.08.2021 declaring Rs. 63,21,450/-, and the assessment was completed on 18.03.2022 accepting the returned income. 4. The Ld. PCIT noted that based on the information available on record, the assessee had received accommodation entries amounting to Rs. 72,00,000/- from the Ashish Begwani Group and its associates, and had allegedly paid Rs. 2,10,000/- in cash @ 3% as commission to the entry provider. The Ld. PCIT also observed that the Assessing Officer had made no additions and acc....