2025 (9) TMI 309

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....pellate Tribunal, `A' Bench, Kolkata (Tribunal) in ITA No. 318/Kol/2021, for the assessment year 2012-13. The revenue has raised the following substantial questions of law for consideration :- i) Whether on the facts and in the circumstances of the case, the Hon'ble ITAT has erred in quashing the order u/s. 263 dated 12.03.2019 by misinterpreting the provision of the sec. 263 of the Act and not recognizing the deficiency in the investigation conducted by the AO based on which the revisionary order u/s 263 was rightly passed by the Ld. PCIT ? ii) Whether on the facts and in the circumstances of the case, the Hon'ble ITAT has erred in quashing the order u/s. 263 dated 12.03.2019 by misinterpreting the provision of the sec. 2....

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....er section 143(3), dated 16.3.2015 and assessed the income at Rs.6,21,01,240/-. 7. The Assessing Officer passed the fresh assessment order under section 143(3) read with section 263 of the Act, dated 21.10.2016 making an addition already made under section 68 of the Act in respect of the share capital/share premium was deleted and income was assessed at Rs. 1240/-. The Assessing Officer called for the necessary details from the assessee and also from the shareholders under section 133(6) of the Act which was duly complied with and by a detailed assessment order dated 21.10.2016 the deletion of addition was made. The PCIT was of the opinion that the assessment order dated 21.10.2016 is erroneous and prejudicial to the interest of the reve....