2022 (10) TMI 1285

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....For the Revenue : Shri T. Shankar ORDER PER SANDEEP SINGH KARHAIL, J.M. The present appeal has been filed by the assessee challenging the impugned order dated 26/03/2021 passed under section 263 of the Income Tax Act, 1961 ('the Act') by learned Principal Commissioner of Income Tax, Mumbai-27 ('learned PCIT'), for assessment year 2015-16. 2. In this appeal, assessee has raised followin....

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....earned PCIT erred in holding that Assessing Officer failed to verify the fact that there is difference between the stamp duty value and agreement value of the flats sold. c. In the facts of the case and in Law, the learned PCIT erred in passing the order u/s 263 by disregarding the fact no notice of hearing u/s 263 was served to the Appellant. d. In the facts of the case and in L....

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....t. 4. During the course of hearing, learned Authorised Representative ('learned AR') submitted that all the details were furnished by the assessee during the course of reassessment proceedings under section 147 of the Act. The learned AR further submitted that after consideration of the details filed by the assessee, the Assessing Officer passed order dated 18/12/2018, under section 143(3) r....

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....ved by the assessee. It has further been submitted that only after the Assessing Officer handed over the physical copy of the impugned order to the assessee, the assessee filed the present appeal. 6. On the other hand, learned Departmental Representative vehemently relied upon the impugned order. 7. Having heard the submissions of both sides and perused the material available on record, we a....