2025 (2) TMI 1851

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.... SINGH GODARA, JUDICIAL MEMBER: This assessee's appeal for Assessment Year 2017-18, arises against the PCIT-1, Agra's in case No. PCIT1/Agra/ITO(OSD)/263/JC/2021-22 dated 31.03.2022, in proceedings u/s 263 of the Income Tax Act, 1961 (in short "the Act"). 2. Case called twice. None appears at the assessee's behest. He is accordingly proceeded ex-parte. 3. We find during the course of hear....

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....is is for the precise reason that apart from reproducing the corresponding show-cause notices which went un-responded by the assessee, there is not even a single instance wherein the learned revisional authority has arrived at any categorical finding on merits after having discussed the relevant error as well as prejudice caused to the interest of the Revenue. Needless to say, the law on exercise ....