2026 (3) TMI 530

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.... PCIT has erred in initiating proceedings u/s. 263 of the Act by wrongly assuming jurisdiction u/s. 263 hence the order passed by PCIT u/s. 263 of the Act is bad in law and void ab initio. 2. Without prejudice to the above ground, on the facts and circumstances of the case and in law, the PCIT has erred in assuming jurisdiction and passing the revisionary order u/s. 263 of the Act inspite of proper verification of documents which were sought from the appellant and accordingly, AO took a permissible view. The order passed by the AO is neither erroneous nor prejudicial to the interest of revenue, hence, the order of PCIT should be set aside. 3. That the PCIT ought to have checked that the assessment order is neither erroneou....

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....reasons: i. Large value receipt or repayment of loans other than through banking channels. ii. Directors in the company are either directors in a company whose registration have been cancelled by MCA also or are of low means. 3.1 Thereafter, the assessment was finalized under section 143(3) read with section 144B of the Income Tax Act, 1961 on 23.2.2024, accepting the return of income of Rs. 88,74,280/-. Ld. PCIT on perusal of the assessment record, has observed that that assessee had shown total turnover of Rs. 28,91,04,467/- whereas freight and labour expenses claimed at Rs. 27,20,11,899/-. During the course of assessment proceedings the AO has not examined the genuineness of these expenses. On perusal of the assessme....

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.... under CASS for limited scrutiny. AO passed the order after making the enquiry in compliance of the order and the assessment order found correct. He also submitted that assessment order was passed after considering the submissions of the assessee. The assessee has submitted all the documents before the AO. The assessee also explained the loan given by the Director Sh. Gopal Singh which was given by the banking transactions. The interest paid after deducing TDS. 5. From the perusal of the order of the PCIT, we note that the case was selected for scrutiny assessment through CASS for the following reasons: i. Large value receipt or repayment of loans other than through banking channels. ii. Directors in the company are eit....