2025 (7) TMI 48

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....(hereinafter referred to as 'the Act'). Heard both the parties. Case file perused. 2. A perusal of the case file reveals at the outset that the learned PCIT has invoked his statutory section 263 revision jurisdiction thereby holding the Assessing Officer's section 154 r.w.s. 143(3) rectification dated 17th May, 2023; framed in the assessee's case, as an erroneous one causing prejudice to the interest of the Revenue. 3. Faced with this situation, leaned counsel vehemently argues that neither the Assessing Officer's above rectification is erroneous in law nor does it cause any prejudice to the interest of the Revenue as what all has been done therein is to acknowledge and ensure that the assessee had filed all the relevant evidence p....

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....reditors. 6.4. The assessee in its reply and submissions has also claimed the entries under consideration to be genuine. The genuineness of the claim of the assessee relating to section 68 of the I. T. Act & requirement of satisfaction of the AO for such credits is a matter which would require deliberation and application of mind. An addition for 6 three credits, found to be not fully explained u/s 68 of the I. T. Act, is not an addition which can be rectified u/s 154 of the I. T. Act as it is a debatable issue. The addition made by the AO is not a mistake which can be rectified as apparent from record. The AO while passing the assessment order has already considered submissions and contentions of the assessee. While passing o....