2025 (7) TMI 588

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....aluru. [ld. PCIT] dated 19.3.2024 wherein it has been held that the assessment order passed by National Faceless Assessment Centre u/s. 147 r.w.s. 144B of the Act dated 12.3.2022 is erroneous and prejudicial to the interests of the revenue and therefore was set aside to make a fresh assessment. The assessee is aggrieved with the same and is in appeal before us. 2. Briefly stated the facts of the case show that assessee is a Proprietor of Prajwal Surgical & Scientifics carrying on business of wholesale and retail sale of surgical and medical equipment, filed his return of income on 1.11.2017 declaring total income of Rs. 21,67,850. As per information that assessee has deposited cash in his bank account with Union Bank of India, Oriental B....

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.... of nature and source of deposits into bank account during the demonetisation period, the AO should have called certificates from the various banks with respect to details of denomination of notes deposited during the specified period. 4. The assessee responded to the above notice stating that complete details were furnished before the AO which was verified and thereafter reassessment order was passed. Therefore, reassessment order is neither erroneous nor prejudicial to the interests of the revenue. The ld. PCIT held that the claim of assessee of receipt of cash received from debtors needs to be verified to ascertain the authenticity of the sources for cash deposits. The ld. AO has accepted the cash deposits made by the assessee without....

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....held to be erroneous and prejudicial to the interests of the revenue by revisionary order passed u/s. 263 of the Act by the ld. PCIT dated 19.3.2024 and the reassessment order passed u/s. 144 r.w.s. 263 r.w.s. 144B of the Act dated 10.3.2025. 9. We find that even in the reassessment order passed in pursuance of the directions u/s. 263 of the Act the returned income of the assessee is accepted. This itself shows that there is no error in the original reassessment order which is not prejudicial to the interests of the revenue. 10. Even otherwise, on the merits of the case, we find that the ld. AO in the original reassessment proceedings has passed the order after making a complete enquiry u/s. 142(1) of the Act. He verified the details ....