2025 (10) TMI 24

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....ppears at the assessee's behest. It appears that the assessee has not appeared on the earlier occasions as well. We thus proceed ex-parte against the assessee. 3. Learned CIT-DR invites our attention to the PCIT, Delhi-1's impugned order invoking section 263 revision jurisdiction dated 25th March, 2021 terming the corresponding regular assessment framed on 26.12.2017 by the Assessing Officer, as an erroneous one causing prejudice to the interest of the Revenue, as under: "7. On perusal of the assessment record and submission made by the assessee. It is observed that the assessee has claimed huge amount, received in cash and kind as exempt perquisites, but the assessee failed to disclose the nature of perquisites and how these are not tax....

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....ssee) has been reflected in the capital account/balance sheet produced by the assessee. The AO has failed to enquire into the issue and take it to logical conclusion 7.4 Further, no reconciliation of the above mismatch has been submitted by the assessee during the assessment proceedings. The assessee has claimed entire TDS, but has not shown the corresponding income. Hence, it is apparent that professional income to the extent of Rs. 16,86,500/-(84,50,000- 67,63,500) has been short declared. 8. Explanation 2 of Section 263 of IT Act, 1961 is reproduced as under: "For the purpose of this section, it is hereby declared that an order passed by the Assessing Officer shall be deemed to be erroneous in so far as it is prejudicial to the ....